People v. Santiago 

Illinois Supreme Court
Criminal Court
Professional Conduct
Motions to Suppress
Citation
Case Number: 
No. 107391
Decision Date: 
Thursday, March 18, 2010
District: 
1st Dist.
Division/County: 
Cook Co.
Holding: 
Appellate court reversed and remanded.
Justice: 
THOMAS
Mother arrested for child endangerment of her infant daughter, and made inculpatory statements to ASA. Motion to suppress properly denied because at time of statements, mother was not represented by counsel. Rule 4.2 of Illinois Rules of Professional Conduct, which prohibits attorney representing a client from communicating with a party on the subject of the representation if attorney knows that party is to be represented by another lawyer in that matter, is inapplicable because civil juvenile proceeding and criminal proceeding are different, even though they were based on same incident, and attorney appointed in child-protection case was not representing the mother in the criminal matter.