James v. Illinois

James v. Illinois Case Brief

United States Supreme Court
493 U.S. 307 (1990)

ISSUE: Should the impeachment exception to the Exclusionary Rule be expanded such that this evidence can be used to impeach all defense witnesses and not just Ds?
HOLDING: No.
FACTS:
  • A group of 8 boys was threatened by a group of 3 boys, and one of the 3 shot and killed one of the other boys and injured another
  • Police then arrested D at his mother's beauty parlor where he had apparently just had his hair died and curled
  • D told the police that his hair used to be reddish-brown
PROCEDURAL HISTORY:
  • Trial Ct. held that statements about hair color were inadmissible at trial
  • D didn't testify but a friendly W did and said that D had black hair on the day of the incident -- prosecution used D's statements to impeach her
  • Ct. App. reversed; Ill. Sup. Ct. reversed again holding that the impeachment exception should be expanded to all defense Ws
REASONING:
  • No expansion: Expansion of the impeachment exception would not promote the truth-seeking function to the same extent as did creation of the original exception, yet it would significantly undermine the deterrent effect of the general exclusionary rule
    • Threat of perjury alone is sufficient to deter defense Ws from intentionally lying on D's behalf
    • Expansion might chill some Ds from presenting their best defense by not calling certain Ws
    • Would significantly weaken deterrence effect of Exclusionary Rule b/c police would stack the deck in favor of the prosecution w/ illegally obtained evidence
COMMENTS:
  • CANNOT use an unwarned statement to impeach a defense witness
    • Probably broadly construed to include not uses any illegally obtained evidence against a defense W
OTHER CASES:
  • Mincey v. Arizona: Use of an involuntary statement against a criminal D at trial is a denial of due process of law and thus cannot be used for impeachment

Leave a Reply