Johnson v. Jaimet

Federal 7th Circuit Court
Criminal Court
Evidence
Citation
Case Number: 
No. 15-2577
Decision Date: 
March 30, 2017
Federal District: 
N.D. Ill., W. Div.
Holding: 
Affirmed

Dist. Ct. did not err in denying defendant’s habeas petition challenging his murder conviction on grounds that trial court improperly excluded inmate from testifying that inmate’s cellmate had hired two men to kill murder victim, and that said men did so. While defendant argued that trial court's exclusion of hearsay testimony was unreasonable application of Chambers, 410 U.S. 284, since cellmate’s confession should have been admitted under due process exception for certain hearsay statements made against penal interest, Ill. Appellate Court could properly find that cellmate’s statement was properly excluded from record since, it constituted unreliable hearsay, where there was no other evidence to corroborate substance of confession, including fact that cellmate subsequently denied making said statement, and where statement was not trustworthy given lack of close relationship between inmate and cellmate. Moreover, other evidence supported defendant’s guilt.