All NRE reports represent a moment in time. For the most accurate data, please search on the Detailed View page. The website is updated daily, frequently with exonerations that occurred in the past.
Convicted of armed robbery in Rock Island, Illinois, in 1940, Roy Eaton was exonerated almost 16 years later after one of the actual culprits confessed to Rock Island State Attorney Bernard J. Moran, who was reinvestigating the case.
On October 4, 1938, two armed men, Louis G. Burrall and Richard Wellington, held up James L. Crooks, a soap salesman, as he sat in his parked car in Rock Island, Illinois, and robbed him of $50 in cash, several checks, and his personal identification papers. More than a year later, on April 12, 1940, Eaton was arrested in Lordsburg, New Mexico, and charged with the crime.
Although Eaton had never been to Rock Island, he registered at a transient camp in Lordsburg under the name Carl Rogers, coincidentally the same name Richard Wellington used when he tried to receive a refund for a train ticket he stole from Crooks. After his arrest for mail fraud on February 15, 1940 under the name Carl Rogers, Eaton caught the attention of the FBI. Eaton’s photograph was then included in a lineup shown to Crooks, and Crooks asserted that Eaton was one of the men who robbed him in 1938. Based on this identification, Eaton was arrested and charged with the robbery on April 17, 1940. Unable to pay for witnesses to travel to Illinois from New Mexico and testify on his behalf, Eaton was sentenced to one-year-to-life for the armed robbery.
After his conviction, Eaton continued to assert his innocence, filing countless motions and appeals. In 1952, Eaton’s petition was heard by the Federal Court of Chicago. Although it was denied, the appointed attorney, Rob J. Gorman, became convinced of Eaton’s innocence and began advocating on his behalf. Together they were able to obtain another federal court hearing for a writ of appeal. Although Eaton’s writ was denied, the opposing state attorney, Bernard J. Moran, also became interested in the case. Moran’s investigation led him to the actual culprit, Louis G. Burrall. Burrall confessed to the crime and named Wellington as his accomplice in exchange for Moran’s agreement not to prosecute him for the robbery. Following Burrall’s confession, charges against Eaton were dismissed and he was released on April 4, 1956 after serving sixteen years in prison for a crime he did not commit.
Following Eaton’s release, his attorney, Gorman, sued the state for his wrongful imprisonment. As a result of special legislation passed by the state legislature, Eaton was awarded a “personal injury” payment of $48,000 on April 2, 1957 for his wrongful imprisonment. This was the first payment by the State of Illinois for a wrongful conviction case.
- Sarah Whitney
The National Registry of Exonerations is a project of the Newkirk Center for Science & Society at University of California Irvine, the University of Michigan Law School and Michigan State University College of Law. It was founded in 2012 in conjunction with the Center on Wrongful Convictions at Northwestern University School of Law. The Registry provides detailed information about every known exoneration in the United States since 1989—cases in which a person was wrongly convicted of a crime and later cleared of all the charges based on new evidence of innocence. The Registry also maintains a more limited database of known exonerations prior to 1989.
We welcome new information from any source about exonerations already on our list and about cases not in the Registry that might be exonerations.