People v. Jackson, 2014 IL App (3d) 120239

Defendant Daniel Jackson was arrested without a warrant and interrogated; suppression motions challenged arrest, evidence, and his March 2, 2010 confession.
Eibeck identified Jackson in a photo array six months after the murder, allegedly triggering a 49 memo and warrantless arrest.
The trial court denied suppression of the arrest and confession, and admitted the videotaped interview into evidence.
Defense sought to highlight involuntariness of the confession and challenged closing argument as coercive, but the court curtailed parts of closing argument.
Jury convicted Jackson of two counts of first-degree murder; sentence aggregated to 65 years on one count.
Appellate court reversed and remanded, finding lack of probable cause tainted the arrest and confession, and plain error affected closing argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did lack of probable cause validate suppression of arrest and confession?	Jackson	People lacked probable cause	Yes; suppression reversed on lack of probable cause
Was the confession admissible after tainted arrest?	Jackson	Confession tainted by unlawful arrest	No; confession inadmissible; convictions reversed
Did closing-argument conduct amount to plain error affecting trial fairness?	People	Plain error due to restricted defense	Plain error found; but remand moot due to other reversals
Was there any valid one-act, one-crime basis to sustain both murders?	People	One murder conviction could stand	Not addressed; convictions reversed on other grounds

People v. Lee, 214 Ill. 2d 476 (Ill. 2005) (deference to suppression-fact findings; mixed questions of law and fact)
People v. Wead, 363 Ill. App. 3d 121 (Ill. App. 4th Dist. 2005) (taint of illegal arrest; need intervening circumstances to purge)
People v. Lara, 2012 IL 112370 (Ill. 2012) (out-of-court confession require corroboration; close evidentiary balance)
People v. Gilliam, 172 Ill. 2d 484 (Ill. 1996) (voluntariness of confession; totality of circumstances)