A South Side woman who told police that she smothered her 11-month-old daughter in 2001 should be released from prison because the only evidence against her was her own confession, a state Appellate Court ruled Wednesday.
In 2004, a Cook County jury found Stacy Samuels guilty of murdering her daughter, Makayla, and a judge sentenced her to 30 years in prison. But the ruling Wednesday by the 1st District Appellate Court in Chicago — if it stands — would reverse that conviction and set Samuels free.
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Samuels’ mother, Debora Williams, said she was relieved by the decision but was waiting to celebrate until she knew for sure that her daughter could come home.
“We’re going to keep supporting her — she’s my daughter,” Williams said in her Englewood home.
Prosecutors said Samuels’ confession in 2001, which included taped statements to a 911 operator, showed that she smothered the child because the baby was inconveniencing her and interrupting her time with her friends.
But Williams and Samuels’ defense attorney say that Samuels is mentally ill and that her confession is not to be believed.
In its ruling, the Appellate Court didn’t voice any opinion on whether Samuels’ confession was true. But in a 12-page opinion, the court agreed with Samuels’ lawyer that Illinois law required prosecutors to present some physical evidence that the baby died from foul play.
“There must be some evidence, independent of the confession, tending to show a crime occurred,” Judge Themis Karnezis wrote for a unanimous three-judge panel.
“The death of an apparently healthy infant may raise suspicions and justify investigation, but it does not by its very nature suggest a [crime], particularly when the medical examiner is unable to rule out natural causes.”
Officials at County State’s Atty. Richard Devine’s office were disappointed and planned to appeal to the Illinois Supreme Court, spokesman Andy Conklin said. He declined to comment further on the ruling.
Samuels’ attorney, Justyna Garbaczewska, said Samuels would be released from prison if the Supreme Court declines to hear the appeal or rules in Samuels’ favor.
Paramedics rushed to Samuels’ home on July 8, 2001, responding to a report that her baby was unconscious, but they were unable to revive the child.
Doctors attributed her death to “possible cardiac arrest.” And after an autopsy, the Cook County medical examiner’s office reached no firm conclusions.
But about two weeks later, Samuels called 911 and confessed to smothering the baby, saying, “I got to tell somebody that [I] killed my baby,” according to a tape played at her trial.
Only after the confession did the medical examiner change the cause of death to homicide by smothering.
Cook County prosecutors argued on appeal that Samuels’ 911 call and other statements to police were too detailed and specific to be made up — and therefore should be deemed reliable.
But the Appellate Court said a long-standing Illinois legal principle requires that prosecutors produce independent evidence — apart from a suspect’s confession — to show that a crime has been committed.
The court had to uphold the legal rule and reverse the conviction, Karnezis wrote. “We make no determination as to [Samuels’] guilt or innocence,” he wrote.
Garbaczewska, Samuels’ attorney, praised the court’s decision, saying there was reason to doubt Samuels’ confession.
“She is mentally ill,” Garbaczewska said. “She has borderline personality disorder and major chronic depression. … Basically the state did not show that a crime occurred.”
Williams said Samuels was high on drugs the night she confessed and was in a state of grief over her baby’s death. She said that her daughter has been diagnosed in prison with bipolar disorder and that her moods change drastically.
“One minute she is happy and smiling and laughing, and then she goes from one end to the other so fast,” Williams said.
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