People v. White
353 Ill. Dec. 517
Ill.2011Background
- White was convicted at a bench trial of first-degree murder for Aramein Brown's death and sentenced to 55 years' imprisonment.
- Defense counsel was present in the room with White but not allowed in the adjacent witness room during two eyewitness identifications.
- Multiple eyewitnesses (Collier, Slaughter, Davis, Brewer) identified White in photo arrays and/or lineups; some later recanted or recanted portions were explored at trial.
- Appellate Court held the lineup doctrine violated the Sixth Amendment, but found the evidence was not so closely balanced as to require relief under plain-error review.
- Illinois Supreme Court granted review to address whether the Sixth Amendment attached at lineup and whether the lineup procedure violated that right; majority affirms the conviction but treats appellate dicta as non‑controlling, and declines to resolve the attachment issue on the merits based on the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sixth Amendment right to counsel attached at the lineup. | White argued attachment occurred at lineup. | White contends counsel must be present and observe identifications. | Attachment not resolved on merits; court proceeded on plain-error grounds; affirmed conviction. |
| Whether excluding defense counsel from the witness room violated the Sixth Amendment. | State policy prohibiting defense in the witness room violated right to counsel. | Counsel's absence impaired meaningful cross-examination of identifications. | Court declined to resolve on merits due to record deficiencies; affirmed without reversing. |
| Whether the lineup error was a “closely balanced” evidentiary issue warranting plain-error relief. | Record shows strong eyewitness identifications; close balance favors defendant. | Error could have affected outcome; plain-error review appropriate. | Evidence was not closely balanced; no prejudice shown under plain-error. |
| Whether the appellate court’sDiscussion of the lineup and attachment issues affected the outcome. | Issues were central to conviction. | Appellate handling of issues was essential to relief. | Majority treated portions as dicta; affirmed conviction; did not grant relief on these issues. |
| Whether the in-court identifications based on prior photo arrays had an independent basis aside from lineup. | Independent basis supported in-court identifications. | Lineup procedures could taint identifications. | Court found independent bases for in-court identifications; lineup impact was de minimis. |
Key Cases Cited
- United States v. Wade, 388 U.S. 218 (Supreme Court, 1967) (establishes independent-basis and pre‑lineup considerations for identification)
- Pearson v. Callahan, 555 U.S. 223 (Supreme Court, 2009) (relaxed Saucier two-step protocol for qualified immunity; discretionary approach guidance)
- Massaro v. United States, 538 U.S. 500 (Supreme Court, 2003) (procedural-default rule to conserve resources; only address issues with potential impact)
- Rothgery v. Gillespie County, 554 U.S. 191 (Supreme Court, 2008) (on presentment triggering Sixth Amendment rights; context for attachment)
- People v. Allen, 222 Ill.2d 340 (Illinois Supreme Court, 2006) (stuns belt/Boose context; plain-error considerations)
- People v. Herron, 215 Ill.2d 167 (Illinois Supreme Court, 2005) (plain-error framework and prejudice analysis)