People v. Parks

Defendant was found guilty of first-degree murder under a theory of accountability and concealment of a homicidal death and was sentenced to 60 years in prison. On appeal, defendant argued that the trial court erred in denying his motion to suppress statements made during a recorded police interview, that trial counsel provided ineffective assistance regarding the motion to suppress statements, that the trial court erred in denying his motion to suppress evidence of statements made during an earlier, unrecorded police interview, that trial counsel was ineffective for not raising the affirmative defense of self-defense, and that the cumulative effects of these errors denied him a fair trial. The appellate court reversed and remanded, finding that the trial court erred when it allowed the admission of defendant’s recorded interview and that defendant was denied the effective assistance of counsel during the interview because counsel violated attorney-client privilege and elicited incriminating statements during the police interview. (LANNERD and DeARMOND, concurring)