People v. White
2011 IL 109689
| Ill. | 2011Background
- Aramein Brown was murdered at a Chicago gas station on Jan. 6, 2003; defendant Kenyatta White was later convicted of first-degree murder after a bench trial; witnesses identified White in photo arrays and a lineup; Martina Brewer’s recantation and fear impacted testimony; Sherry Collier identified White in photos and in court; the defense challenged lineup procedures and the presence of counsel during identification; the appellate court found the evidence not closely balanced, and this Court granted review to address attachment of the Sixth Amendment right to counsel and related issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Attachment of Sixth Amendment right to counsel at lineup | Appellate court erred by not recognizing attachment | Right attached at lineup; exclusion violated rights | Attachment not necessary to resolve outcome; affirmed ruling on merits |
| Whether lineup-related error was plain error under closely balanced evidence | Evidence was closely balanced, error could tip verdict | Not closely balanced; error inconsequential | No plain-error; evidence weighed against defendant so no prejudice |
| Whether the appellate court’s dicta on attachment and lineup procedure was proper | Dicta review necessary to resolve constitutional issue | Record unreliability; issue not essential | Dicta analysis rejected; affirmed without addressing merits of attachment issue |
Key Cases Cited
- United States v. Wade, 388 U.S. 218 (1967) (identification procedures; independent basis for in-court identifications)
- Pearson v. Callahan, 555 U.S. 223 (2009) (relaxation of rigid constitutional protocol in qualified-immunity context)
- Massaro v. United States, 538 U.S. 500 (2003) (procedural-default rule to conserve resources; avoid unnecessary constitutional ruling)
- People v. Allen, 222 Ill. 2d 340 (2006) (stun belt Boose analysis; plain-error interplay)