JAMES V. ILLINOIS 493 U.S. 307 (1990) CASE BRIEF

JAMES V. ILLINOIS

493 U.S. 307 (1990)

NATURE OF THE CASE: A trial court permitted the State to introduce James' (D) illegally obtained statements to impeach the testimony of a defense witness. D was convicted. The Illinois Appellate Court reversed the convictions on the ground that the exclusionary rule barred the admission of the illegally obtained statements for the purpose of impeaching a defense witness' testimony. The State Supreme Court reversed, reasoning that the impeachment exception to the exclusionary rule - which permits the prosecution to introduce illegally obtained evidence to impeach the defendant's own testimony - should be expanded to include the testimony of other defense witnesses in order to deter the defendant from engaging in perjury 'by proxy.' The Supreme Court granted certiorari.

FACTS: Eight young boys returning were confronted by a trio of other boys who demanded money. The eight boys refused to comply and one member of the trio produced a gun and fired into the larger group, killing one boy and seriously injuring another. When the police arrived, the remaining members of the larger group provided eyewitness accounts of the event and descriptions of the perpetrators. Fifteen-year-old Darryl James (D) was taken into custody as a suspect in the shooting. D was found at his mother's beauty parlor sitting under a hair dryer; when he emerged, his hair was black and curly. After placing D in their car, the detectives questioned him about his prior hair color. He responded that the previous day his hair had been reddish brown, long, and combed straight back. The detectives questioned D again later at the police station, and he further stated that he had gone to the beauty parlor in order to have his hair 'dyed black and curled in order to change his appearance.' D was indicted James for murder and attempted murder. D moved to suppress the statements regarding his hair, contending that they were the fruit of a Fourth Amendment violation because the detectives lacked probable cause for his warrantless arrest. The trial court sustained this motion and ruled that the statements would be inadmissible at trial. Five members of the larger group of boys testified for the State, and each made an in-court identification of the defendant. Each said that the shooter had 'reddish' hair, worn shoulder length in a slicked-back 'butter' style. They had seen D several weeks earlier at a parade, where D had that hair color and style. At trial, D's hair was black and worn in a 'natural' style. D called as a witness Jewel Henderson, a friend of his family. Henderson testified that on the day of the shooting she had taken D to register for high school and that, at that time, his hair was black. P sought to introduce his illegally obtained statements as a means of impeaching the credibility of Henderson's testimony. The trial court overruled D's objection. D was convicted of both murder and attempted murder and sentenced to 30 years' imprisonment. The Illinois Appellate Court reversed and ordered a new trial. The exclusionary rule barred admission of D's illegally obtained statements for the purpose of impeaching a defense witness' testimony and that the resulting constitutional error was not harmless. The Illinois Supreme Court reversed. The court reasoned that, in order to deter the defendant from engaging in perjury 'by proxy,' the impeachment exception to the exclusionary rule ought to be expanded to allow the State to introduce illegally obtained evidence to impeach the testimony of defense witnesses other than the defendant himself. The Supreme Court granted certiorari.

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