James v. Illinois

Maintained the exclusionary rule should not be compromised in the context of the courtroom setting.

On 30 August 1982, Darryl James was reported to have killed one youth and critically injured another with a gun. James allegedly told detectives, when he was taken into questioning the day after the murder as a suspect, that he had deliberately altered his hair style since the shooting. Because it was determined that James was arrested without a warrant or probable cause, his statements about changing his hair were deemed inadmissible in his subsequent trial. Once the case did go to trial, five witnesses from the original group accosted during the shooting testified that one member of the group who had committed murder, allegedly James, had, in fact, "slicked back, shoulder-length, reddish hair." James wore black curly hair during police questioning, as well as at trial where he preferred to remain silent. A witness, however, Jewel Henderson, was called on his behalf, testifying that James's hair the day of, and prior to the shooting, was black and curly--just as it appeared in the courtroom. At that point, the court permitted the state to introduce James's illegally obtained statements to impeach Henderson's testimony. James was convicted on both counts.

In 1987 the Illinois Appellate Court turned over James's conviction because of the exclusionary rule which states, "The rule of constitutional law that evidence secured by the police by means of an unreasonable search and seizure, in violation of the Fourth Amendment, cannot be used as evidence in a criminal prosecution." In 1989 the Illinois Supreme Court followed, reversing on the premise that the "impeachment exception to the exclusionary rule should be expanded to include the testimony of other defense witnesses in order to deter the defendant from engaging in perjury `by proxy.'" Supporters of the ruling noted that the decision would discourage a witness from committing perjury. Detractors noted that police misconduct would be encouraged in such situations, ultimately strengthening the prosecution's case.

The U.S. Supreme Court agreed to review the decision. Justice Brennan delivered the opinion of the Court majority on 4 June 1990. Brennan noted "We believe that this proposed expansion would frustrate rather than further the purposes underlying the exclusionary rule." He went on to say, "Thus, the truth-seeking rationale supporting the impeachment . . . does not apply to other witnesses with equal force." Brennan added " . . . much if not most of the time, police officers confront opportunities to obtain evidence illegally after they have already legally obtained . . . sufficient evidence to sustain a prima facie case." The opinion of the Court noted that " . . . Expanding the impeachment exception to encompass the testimony of all defense witnesses likely would chill some defendants from presenting their best defense . . . through the testimony of others." Finally, Brennan stated, "So long as we are committed to protecting the people from the disregard of their constitutional rights during the course of criminal investigations, inadmissibility of illegally obtained evidence must remain the rule, not the exception."

Justice Kennedy gave the dissenting opinion of the minority. He stated, " . . . the line drawn by today's opinion grants the defense in a criminal case broad immunity to introduce whatever false testimony it can produce from the mouth of a friendly witness." He went on to explain that the "exclusionary rule does not apply where the interest in pursuing truth or other important values outweighs any deterrence of unlawful conduct that the rule might achieve." Specifically, Kennedy believed that James's statements to the police about the appearance of his hair should have been admissible, thus, agreeing with the Illinois State Supreme Court's decision. The U.S. Supreme Court's majority decision, however, furthered the trend of erring in favor of the accused in order to avoid potential transgressions by law enforcement.