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United States v. West - 813 F.3d 619 (7th Cir. 2015)

Rule:

Regarding expert testimony that a defendant is a suggestible, mentally ill person with a low IQ, testimony of this type is highly relevant to the jury's consideration of a defendant's "personal characteristics"—exactly the sort of evidence that a jury ought to be permitted to hear to assess the trustworthiness of a defendant's statements to the police. 

Facts:

The Chicago Police Department dispatched a report that several suspicious men were seen carrying televisions in the 1300 block of West 92nd Street. An earlier dispatch that day had reported a burglary and theft of two televisions in the same area. Police officers responded to the neighborhood and saw several men carrying televisions into an apartment building located at 1330 W. 92nd Street. They entered the building and looked through the open door of one of the apartments, where they saw two televisions. They entered the apartment and detained everyone there, including defendant Antonio West, who was holding a television. The officers handcuffed West and moved him to their squad car. Another officer brought the burglary victim to the scene to identify the stolen property. Based on the serial number, the victim identified one of the televisions in the apartment as his. West, still in the back of the squad, was given Miranda warnings, waived his rights, and agreed to speak to the officers. He denied any involvement in a burglary but said he was paid $10 to carry the television into the apartment. The officers asked him where the second stolen television was. West hesitated at first, but then said it was in the attic of his house. West consented to a search and gave the officers an address: 9238 S. Loomis Street. He signed a consent-to-search form for that address, which also appeared on his state identification card. Although the officers didn't know it at the time, the Loomis Street residence was the home of West's late father, who had died about six months earlier. The officers went to the Loomis Street address and found the stolen television and an M1 carbine rifle. West ultimately admitted to officers that the rifle belonged to him.

West was indicted with possessing a firearm as a felon. At trial in federal district court, his attorney sought a motion to suppress West's admission as to the rifle, on grounds that expert testimony established that West had a low IQ, suffered from mental illness, and scored high on a psychological test that measured a person's degree of suggestibility. The judge denied the motion, concluding that despite such deficits, West was competent to understand and intelligently waive his rights and that his statements to the police and the consent to search were knowing and voluntary. During trial, the defense called West's cousin to establish that West lived in a nursing home due to his mental illness. The judge disallowed that testimony, but he did allow the cousin to testify that West lived at an address other than the Loomis Street residence where the gun was found. The defense also sought to establish that West had a state identification card listing him as disabled, but the judge excluded that evidence. West was convicted and sentenced to 15 years in prison. West appealed, arguing that that the exclusion of the expert testimony was reversible error.

Issue:

Did the trial court err in excluding the expert testimony?

Answer:

Yes.

Conclusion:

The appellate court reversed the trial court's judgment and remanded the matter for a new trial. The court held that where officers found an old gun that apparently belonged to West's late father in the attic of the family home during a consensual search for a stolen television and the Government's case for possession under 18 U.S.C.S. § 922(g)(1) rested heavily on West's admission to the police that the gun was his, the exclusion of expert testimony regarding defendant's low IQ and mental illness was reversible error because the expert's testimony was clearly relevant and admissible on the issue of the reliability of West's confession.

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