People v. Harris, 977 N.E.2d 811

Defendant Annette Harris convicted of felony murder predicated on armed robbery after bench trial.
Key evidence largely based on Harris’s inculpatory statements across multiple interviews.
April 20-21, 2007 custodial interrogations not videotaped, raising 103-2.1 concerns.
Harris argued she invoked right to counsel during later custodial interrogation but questioning continued.
Court reversed and remanded for new trial; mittimus fulfillment deemed moot after reversal.
Trial court’s suppression rulings and evidentiary weight of confessions were central to reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the April 20-21 confession admissible under 103-2.1?	State contends no custodial interrogation for murder; statements voluntary.	Statements were custodial, not videotaped, presumptively inadmissible under 103-2.1.	Custodial interrogation; non-recorded confession inadmissible.
Did Harris’s invocation of the right to counsel on May 1 halt questioning?	Invocation was ambiguous; police appropriately resumed questioning.	Invocation was unequivocal; continued questioning violated Edwards v. Arizona.	Invocation was unequivocal; post-invocation statements inadmissible.
Are the post-invocation videotaped statements admissible after Edwards v. Arizona guidance?	Voluntariness and reliability sufficient under 103-2.1(f).	After Edwards, post-invocation statements should be suppressed; not harmless error.	Remand for new trial; post-invocation statements suppressed; not harmless.
Was the evidence sufficient to prove armed robbery as the predicate for felony murder?	Circumstantial proof showed taking of Williams’s money and defendant’s role.	No clear evidence money was taken; insufficient for armed robbery predicate.	Sufficient circumstantial evidence; armed robbery predicate proven.

People v. Slater, 228 Ill. 2d 137 (Ill. 2008) (deference to trial court, de novo legal review of suppression)
People v. Wheeler, 281 Ill. App. 3d 447 (Ill. App. 1996) (station-house questioning supports custody finding)
Lopez, 229 Ill. 2d 322 (Ill. 2008) (custody determination and Edwards implications)
Schuning, 399 Ill. App. 3d 1073 (Ill. App. 2010) (timing and clarity of invocation of counsel)
Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (warned about interrogation and waiver procedures)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (unequivocal invocation required for cessation of questioning)
In re Christopher K., 217 Ill. 2d 349 (Ill. 2005) (doctrine on waiver and unequivocal invocation)
Slater, 228 Ill. 2d 137 (Ill. 2008) (precedent on voluntariness and suppression standard)