James v. Illinois

In James v. Illinois, 493 U.S. 307 (1990), the Supreme Court held that, while the impeachment exception to the exclusionary rule permits the prosecution to introduce illegally obtained evidence to impeach a defendant's testimony, that exception does not permit the prosecution to use illegally obtained evidence to impeach the testimony of other defense witnesses. In James v. Illinois, the defendant's inculpatory statements -- that his hairstyle on the day of a shooting matched witnesses' descriptions of the shooter's hair -- were suppressed because they were obtained in violation of the Fourth Amendment. The defendant did not testify; however, a defense witness testified that the defendant's hairstyle on the day of the shooting did not match the description of the hairstyle of the shooter. Over the defendant's objection, the state then introduced the defendant's statements for the purpose of impeaching the witness' testimony, and the defendant was convicted. In reversing that conviction, the Supreme Court stated: Expanding the class of impeachable witnesses from the defendant alone to all defense witnesses would create different incentives affecting the behavior of both defendants and law enforcement officers. As a result, this expansion would not promote the truth-seeking function to the same extent as did creation of the original exception, and yet it would significantly undermine the deterrent effect of the general exclusionary rule. Hence, we believe that this proposed expansion would frustrate rather than further the purposes underlying the exclusionary rule. James v. Illinois, supra, 493 U.S. at 313-314. The Supreme Court further reasoned that the threat of criminal prosecution for perjury would be sufficient to deter defense witnesses from intentionally lying on the defendant's behalf, and concluded that the impeachment exception should not be expanded because defendants, fearing the impeachment of their witnesses with illegally obtained evidence, would be more hesitant to call witnesses who would otherwise offer probative evidence.