Posted by As many in the Illinois legal community know, the police officer who shot and killed Sonya Massey was convicted of second-degree murder by a Peoria County jury in October 2025. Sean Grayson, a former Sangamon County Sheriff’s Deputy responded to Massey’s 911 call reporting an intruder at her home. Grayson and his partner entered Massey’s home where she was in the kitchen near a boiling pot of water. Body camera footage shows Grayson and his partner laughing about the pot of boiling water, to which Massey replies “I rebuke you in the name of Jesus.” Grayson then yells at her to drop the pot as she reaches for it and Grayson opens fire. The footage is horrifying, to say the least.
In the aftermath of this murder, national outrage erupted over a police officer shooting an otherwise unarmed black woman in her own kitchen. Protestors across the Chicagoland area demanded action, and, more than a month after the shooting, the State charged Grayson with first-degree murder.
With the trial concluded, and Grayson convicted, it is a good moment to reflect on the proceedings and their implications. First, it is important to understand what Grayson was charged with and what he was convicted of. In Illinois, first-degree murder requires an intent to kill or knowledge that one’s actions will cause death or great bodily harm (720 ILCS 5/9-1(a)(1)(2)). By contrast, second-degree murder requires the State to prove all the elements of first-degree murder, but the defendant demonstrates either (1) that they acted under intense passion caused by serious provocation, or (2) they acted under the belief that the killing was necessary to defend themselves but that belief was unreasonable (720 ILCS 5/9-2(a)(2)).
Under this statutory scheme, the trial was a win for the defense, says Chicago-Kent College of Law Professor and renowned trial attorney Richard Kling. Ultimately, the defense was able to convince the jury that Grayson believed that the was shooting in self-defense. Professor Kling finds that claim hard to believe given the circumstances of the shooting, but he acknowledges that juries are highly unpredictable.
Even though this may seem like a win for the defense, Grayson, a former police officer, was still convicted of murder. And that outcome is rare, according to Zach Sommers, a criminal law scholar and Professor at Chicago-Kent. Even though many have deemed this killing racially motivated, Sommers notes “in many ways, the deck is stacked against victims of police shootings, no matter their race.” He explains that “law enforcement kills approximately 1,000 people nationwide every year, and arrests of the officer(s) involved are made in somewhere on the order of 1-2% of those cases. Convictions are even rarer; and convictions for murder (as opposed to lesser crimes) are even more uncommon, constituting fractions of a percentage point of total fatal police shootings.”
Another important issue that caught my attention with this trial was police officers holding fellow officers accountable. Unfortunately, in many police departments, there is an unwritten rule that forbids officers from reporting other officers’ misconduct (Torres & Curiel, Cracking the Blue Wall of Silence: A Necessary Step for Police Reform, American Bar Association, September/October 2023). This phenomenon is sometimes referred to as the “blue wall of silence.” In the Sonya Massey case, however, that blue wall was broken when Grayson’s partner testified against him at trial. As Professor Sommers notes, the testimony of Grayson’s partner was especially damaging to the defense’s case when the partner testified that he did not view Massey as a threat. Greater study and reform of this “blue wall” can help society hold officers accountable when necessary while still protecting them when their actions are justified.
The trial of the police officer who killed Sonya Massey was an important step forward for the future of police accountability. Even though some close to Massey’s family have called the second-degree murder verdict a miscarriage of justice, I believe that this was an example of the system working the way it should. The question before the jury was a narrow one, and by all accounts, they fulfilled their duty to come to a fair and lawful verdict. Only time will tell what the future holds for police accountability.
Shmuel Wyckoff is a dedicated law student at Chicago-Kent College of Law and an aspiring appellate attorney. He has a passion for exploring issues in criminal law, constitutional law, and appellate litigation. Shmuel’s goal is to provide readers with engaging discussions of current issues in the law while also empowering readers with practical legal information. While not immersed in classes and externship work, Shmuel enjoys watching football and baseball, cooking, reading, and hiking.