James attempted to suppress the statements he had previously made about his hair as being "fruit of the poisonous tree" obtained in violation of the Fourth Amendment, as there had been no probable cause for his arrest.

At trial the state's witnesses testified that the shooter had reddish hair that was slicked back.

The Illinois Appellate Court reversed the conviction, holding that James' statements should have been suppressed as "fruit of the poisonous tree", even to impeach Henderson.

The Illinois Supreme Court reversed this decision, holding that there was no Fourth Amendment violation and thereby reinstating the murder conviction.

Justice Brennan noted that this expansion "would frustrate rather than further the purposes underlying the exclusionary rule.