People v. Suggs

Illinois Appellate Court
Criminal Court
Confessions
Citation
Case Number: 
2016 IL App (2d) 140040
Decision Date: 
Tuesday, June 28, 2016
District: 
2d Dist.
Division/County: 
Lake Co.
Holding: 
Affirmed in part and vacated in part (Case No. 2-14-0040); and Affirmed (Case No. 2-14-0041).
Justice: 
BIRKETT

Defendant was convicted, after jury trial, of first-degree murder. After that trial, Defendant accepted stipulated bench trial in another case, in which he was convicted of attempted murder and attempted armed robbery while armed with firearm. Defendant was properly held on 1 offense but had not received probable-cause determination on a 2nd offense before confessing to 2nd offense after lengthy interrogation.  The fact that Defendant had been lawfully detained dispels any concerns about unlawful detention. Considering totality of circumstances, including that Defendant was then age 23 and of normal intellect and physical health, and that Defendant was actively interrogated over 3 days during a 4-day span (but with breaks and food and drink), Defendant's confession was voluntary.(BURKE and HUDSON, concurring.)