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James v. Illinois | 493 U.S. 307 (1990)
The impeachment exception to the exclusionary rule permits prosecutors to impeach a criminal defendant’s testimony using unlawfully obtained evidence. This exception prevents defendants from giving testimony that contradicts the suppressed evidence and relying on the prosecution’s inability to challenge their testimony using that evidence. In James versus Illinois, the Supreme Court considered the boundaries of this exception.
On August thirtieth, nineteen-eighty-two, Geliria Boyd and Delbert Collins were walking home from a party with a group of friends when three boys approached, demanding money. When the group refused, one of the boys fired several gunshots, killing Boyd and critically injuring Collins. Boyd and Collins’s friends provided descriptions of the three boys to officers at the scene.
The next day, Darryl James was identified as a suspect in the shooting. Detectives located James at his mother’s hair salon and took him into custody. The detectives questioned James about his hair, which was currently black and curly. James replied that his hair had previously been straight and reddish-brown and that he’d had it dyed and curled to alter his appearance.
James was subsequently indicted for Boyd’s murder and for the attempted murder of Collins. The trial court granted James’s motion to suppress his statements, ruling they were made during a warrantless arrest without probable cause.
At trial, five of Boyd and Collins’s friends who had been present during the shootings testified for the prosecution. Each of the witnesses identified James as the shooter and testified that the shooter had reddish-brown hair. Although James didn’t testify, family friend Jewel Henderson testified that she’d seen James on the day of the shootings and that on that day his hair had been black. Over the defense counsel’s objection, the trial court permitted the prosecution to impeach Henderson’s testimony using James’s unlawfully obtained statements to the detectives regarding his hair. James was convicted on both charges.
On appeal, the Illinois Appellate Court reversed James’s convictions, ruling that the impeachment exception to the exclusionary rule is limited to impeaching a defendant’s testimony and can’t be used to impeach defense witnesses. The Illinois Supreme Court reversed, ruling that the exception applies to all witnesses testifying for the defense. The United States Supreme Court granted cert.
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