* On the night of August 30, 1982, eight young boys returning home from a party were confronted by a trio of other boys who demanded money. When the eight boys refused to comply, 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.
The next evening, two detectives of the Chicago Police Department took 15-year-old Darryl James into custody as a suspect in the shooting. James was found at his mother's beauty parlor sitting under a hair dryer; when he emerged, his hair was black and curly. After placing James 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 James 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." App. 11.
The State subsequently indicted James for murder and attempted murder. Prior to trial, James 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. After an evidentiary hearing, the trial court sustained this motion and ruled that the statements would be inadmissible at trial.
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 testified that the person responsible for the shooting had "reddish" hair, worn shoulder length in a slicked-back "butter" style. Each also recalled having seen James several weeks earlier at a parade, at which time James had the aforementioned hair color and style. At trial, however, his hair was black and worn in a "natural" style. Despite the discrepancy between the witnesses' description and his present appearance, the witnesses stood firm in their conviction that James had been present and had fired the shots.
James did not testify in his own defense. He called as a witness Jewel Henderson, a friend of his family. Henderson testified that on the day of the shooting she had taken James to register for high school and that, at that time, his hair was black. The State then sought, over James' objection, to introduce his illegally obtained statements as a means of impeaching the credibility of Henderson's testimony. After determining that the suppressed statements had been made voluntarily, the trial court overruled James' objection. One of the interrogating detectives then reported James' prior admissions that he had reddish hair the night of the shooting and he dyed and curled his hair the next day in order to change his appearance. James ultimately was convicted of both murder and attempted murder and sentenced to 30 years' imprisonment.
On appeal, the Illinois Appellate Court reversed James' convictions and ordered a new trial. 153 Ill.App.3d 131, 106 Ill.Dec. 327, 505 N.E.2d 1118 (1987). The appellate court held that the exclusionary rule barred admission of James' illegally obtained statements for the purpose of impeaching a defense witness' testimony and that the resulting constitutional error was not harmless.
Jurisdiction: U.S. Supreme Court
Related Categories: Constitutional Law , Criminal Justice , Damages , Education , Government / Politics