Illinois Appellate Court
Criminal Court
Motion to Suppress
Defendant was found guilty of being an armed habitual criminal and was sentenced to 12 years in prison. On appeal, he argued that the trial court erred by denying his motion to suppress statements, admitting evidence of recovered ammunition, and failing to account for mitigating factors during his sentencing. The appellate court reversed and remanded, finding that defendant’s statements should have been suppressed because they were obtained during a custodial interrogation without Miranda warnings and were not admissible under the public safety exception. (LAMPKIN and REYES, concurring)