## Facts

- Darryl James was indicted in Illinois for murder and attempted murder arising from a shooting that killed one boy and seriously injured another.
- Police arrested James the day after the shooting; during custody he made statements describing that he had recently dyed and curled his hair to change his appearance.
- The trial court found the arrest unlawful and suppressed James’s hair-related statements as fruits of an unlawful arrest under the Fourth Amendment.
- At trial, multiple eyewitnesses described the shooter as having slicked-back, shoulder-length, reddish hair and identified James as the shooter.
- James did not testify; the defense called Jewel Henderson, who testified that James had black hair on the day of the shooting.
- Over defense objection, the trial court allowed the prosecution to introduce the previously suppressed statements solely to impeach Henderson’s testimony.
- James was convicted; the Illinois Appellate Court reversed, but the Illinois Supreme Court reinstated the convictions by extending the impeachment exception to all defense witnesses.
- The U.S. Supreme Court granted review.

## Issues

1. Whether the Fourth Amendment exclusionary rule permits the prosecution to use illegally obtained evidence to impeach the testimony of a defense witness other than the defendant.

## Decision

- The Supreme Court reversed, holding 5–4 that the impeachment exception to the exclusionary rule may not be extended to impeach defense witnesses other than the defendant.
- The Court ruled that the Illinois Supreme Court erred by allowing suppressed, unlawfully obtained statements to impeach Henderson.
- The Court left intact the narrow rule permitting illegally obtained evidence to impeach a defendant’s own testimony.

## Legal Principles

- The exclusionary rule’s primary function is deterrence of unconstitutional police conduct; exceptions are narrowly limited.
- Illegally obtained evidence may be used to impeach the defendant’s testimony, but that exception does not extend to impeachment of other defense witnesses.
- Expanding impeachment to all defense witnesses would materially weaken deterrence by increasing the potential uses of tainted evidence.
- Allowing such impeachment risks chilling the defense from calling witnesses, thereby impairing the defense’s ability to present probative evidence.

## Conclusion

The Court limited the Fourth Amendment impeachment exception to the defendant’s own testimony and barred use of unlawfully obtained evidence to impeach other defense witnesses, emphasizing deterrence and the risk that broader impeachment would discourage the defense from presenting witnesses.


James v. Illinois, 493 U.S. 307 (1990)