People v. Jackson
22 N.E.3d 526
Ill. App. Ct.2014Background
- People charged Jackson with four counts of first-degree murder; Counts III and IV involve Harvey shooting.
- Pretrial motions moved to quash arrest and suppress evidence and suppress statements; Miranda waiver and coercion alleged.
- Arrest was warrantless; suppression hearing reviewed credibility of Eibeck’s identification and probable cause.
- DVD of March 2, 2010 interrogation showed potential coercion and defense argued it undermined voluntariness.
- Trial court denied suppression; jury found Jackson guilty on two murder counts; 65-year sentence imposed on one count.
- Appellate court reversed convictions and remanded for proceedings after concluding lack of probable cause and improper closing argument handling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the arrest was supported by probable cause. | People contends probable cause existed via Eibeck identification. | Jackson contends no probable cause; arrest was unlawful. | Probable cause lacking; warrantless arrest invalid. |
| Whether the confession was admissible after suppression ruling. | People asserts confession admissible as subsequent to lawful arrest. | Jackson argues confession tainted by unlawful arrest/coercion. | Confession inadmissible; tainted by unlawful arrest. |
| Whether the closing argument conduct amounted to plain error. | State argues no reversible error post-remand. | Defense claim of silencing questioning emphasized unreliability of confession. | Plain error found; closing argument improperly curtailed defense. |
Key Cases Cited
- People v. Lee, 214 Ill. 2d 476 (2005) (deference to trial court findings; suppression review standard)
- People v. Hackett, 2012 IL 111781 (2012) (mixed questions of law and fact; deference to credibility)
- People v. Luedemann, 222 Ill. 2d 530 (2006) (credibility and suppression standard clarified)
- People v. Arnold, 349 Ill. App. 3d 668 (2004) (reliability of third-party information in probable cause)
- People v. Adams, 2012 IL 111168 (2012) (totality of circumstances; closeness of the evidence)
- People v. Lara, 2012 IL 112370 (2012) (out-of-court confession corroboration requirements)
- People v. Jefferson, 184 Ill. 2d 486 (1998) (rights to challenge voluntariness of confession)
- Gilliam, 172 Ill. 2d 484 (1996) (voluntariness factors for confessions; totality of circumstances)
- Escobedo v. Illinois, 378 U.S. 478 (1964) (right to counsel and interrogation pressures)
- Connelly v. United States, 479 U.S. 157 (1986) (coercion and reliability concerns about confessions)
- Patterson, 217 Ill. 2d 407 (2005) (right to remain silent; invocation principles)