Reversal of Court's Decision That Confession Was Extracted Using Physical Violence

In People v. Richardson, 376 Ill. App. 3d 537, 875 N.E.2d 1202, 314 Ill. Dec. 915 (2007), the Court reversed defendant's conviction on the basis that the trial court erred in denying his motion to suppress where the State failed to prove by clear and convincing evidence that defendant's eye injury was not inflicted in order to obtain a confession. The State was granted leave to appeal to the Illinois Supreme Court. People v. Richardson, 226 Ill. 2d 627, 882 N.E.2d 81, 317 Ill. Dec. 507 (2008). Before our supreme court, the State argued that defendant's inculpator statement was voluntary and not coerced. The supreme court agreed and reversed this court's decision, instructing this court to consider defendant's remaining contentions. People v. Richardson, 234 Ill. 2d 233, 917 N.E.2d 501, 334 Ill. Dec. 675 (2009).