People v. Sapp

We granted certiorari in these two cases to review the orders of the Lake County District Court affirming orders of a county court suppressing evidence in the prosecutions of two law enforcement officers for False Reporting to Authorities 1 and Second Degree Official Misconduct. 2 The county court concluded that the officers’ statements were compelled by the threat of discharge from their employment. We adopt a two-prong test to determine whether statements are compelled by threat of discharge from employment: (1) a person must subjectively believe that he will be fired for asserting the…