James v. Illinois

Darryl James (defendant) was a murder suspect. When the police found James the day after the murder, he was in a beauty parlor getting his hair curled and dyed black. The police took James into custody, and James told the officers that his hair was previously reddish-brown and straight. He stated that he dyed his hair black “to change his appearance.” At a pretrial hearing, the trial court ruled these statements inadmissible as the fruit of a warrantless arrest that violated James’s Fourth Amendment rights. At trial, eyewitnesses for the prosecution identified James as the shooter, testified that the shooter had reddish hair, and testified that they had seen James with reddish hair prior to the shooting. James did not testify. Jewel Henderson, a family friend, testified in James’s defense. Henderson stated that on the day of the shooting, James’s hair was black. The prosecution sought to impeach Henderson’s testimony with James’s statements to the officers when he was arrested. The trial court admitted James’s statements for impeachment purposes. James was convicted. The Illinois Appellate Court reversed, finding that the exclusionary rule did not allow illegally obtained statements to be used for impeaching a defense witness’s testimony. The Illinois Supreme Court reversed and reinstated James’s conviction, finding that the impeachment exception to the exclusionary rule applied to Henderson’s testimony. The United States Supreme Court granted certiorari.