People v. Hunt
360 Ill. Dec. 774
| Ill. | 2012Background
- Defendant Hunt, arrested for Beckley’s murder, faced numerous counts including 33 murder charges and related offenses.
- Hunt moved to suppress statements and recordings from court-ordered overhears with an informant who was wearing a wire.
- Interlocutory appeals followed: appellate court affirmed suppression; Illinois Supreme Court granted review to assess McCauley grounds.
- During custodial interrogation at the station, detectives questioned Hunt after Miranda warnings; later, a lineup and a concealed-wire overhear with Mycal Davis occurred.
- Counsel arrived at the station during one overhear; Hunt invoked rights at a later time during the same session.
- The trial court suppressed statements after concluding McCauley required timely access to counsel; appellate court affirmed suppression on McCauley grounds; the Supreme Court reversed as to McCauley applicability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McCauley governs suppression of overheard statements | Hunt's statements were improperly suppressed under McCauley. | Under McCauley, absence of timely counsel access violated Hunt’s rights. | McCauley does not apply; statements not suppressed on McCauley grounds. |
Key Cases Cited
- People v. McCauley, 163 Ill.2d 414 (1994) (state constitutional right to counsel during custodial interrogation)
- Perkins v. United States (Perkins I), 496 U.S. 292 (1990) (undercover inmate questioning not Miranda-triggered)
- People v. Perkins (Perkins II), 248 Ill.App.3d 762 (1993) (Illinois appellate decision overruling federal dicta; confers McCauley-like restrictions)
- In re Moran v. Burbine, 475 U.S. 412 (1986) (fifth amendment counsel right not triggered by police actions absent interrogation)
- Illinois v. Perkins, 496 U.S. 294 (1990) (undercover interrogation doctrine; not custodial interrogation)
- Becker Manning (People v. Manning), 182 Ill.2d 193 (1998) (Miranda not implicated in conversations with undercover agents)
- United States v. Howes, 132 S. Ct. 1195 (2012) (custody standard under Miranda context)