Lekas v. Illinois

Background

An Illinois man was arrested at night without a warrant and held for about twelve hours during intermittent questioning. The Illinois appellate court assumed the arrest lacked probable cause but still allowed the in-custody confession after police confronted him with new evidence and a codefendant’s confession. The Supreme Court refused to review that ruling, leaving the appeals court’s decision in place.

Reasoning

The central question was whether confronting a detained person with new evidence or another person’s confession can erase the effects of an allegedly illegal arrest. The Illinois court said yes and admitted the confession. Other state courts have disagreed and would treat such a confession as still tainted by the illegal arrest. Justice White’s dissent argued the Court should hear the case because the issue affects how broadly the Constitution protects against unlawful arrests.

Real world impact

Because the Supreme Court declined to act, courts remain split and the rule depends on where a case is heard. In Illinois the confession stands; in other States similar confessions might be excluded. The dissent noted that police could likely have presented the detainee to a magistrate during the twelve-hour period, so the decision may affect when and how police use evidence gathered after suspect arrests. Justice White described the conflict as an important constitutional question.

Dissents or concurrances

Justice White dissented from the denial of review and would have granted review, stressing the state split and saying confronting a continuously detained suspect should not automatically purge the arrest’s taint.