People v. Patterson

This case presents question as to whether trial court properly admitted confession of 15-year-old defendant, who was under wardship and custody of DCFS, and who had been charged with aggravated criminal sexual assault, under circumstances where police did not notify defendant’s non-custodial biological parents prior to commencing questioning of defendant and only gave defendant’s caseworker two minutes notice prior to commencing questioning. While Appellate Court agreed with govt. that defendant understood his rights prior to instant questioning, Appellate Court nevertheless found that statement should be suppressed since police made no reasonable attempt to contact concerned adult prior to initiating questioning of defendant. Court further found that trial court erred in finding that Rape Shield Law precluded defendant from testifying that redness on victim’s cervix was result of victim having recent sexual intercourse with her boyfriend.