Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
Smith's Criminal Case Compendium
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This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.
Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.
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Advice by law enforcement officers that the defendant had “the right to talk to a lawyer before answering any of [the law enforcement officers’] questions” and that he could invoke this right “at any time . . . during th[e] interview,” satisfied Miranda’s requirement that the defendant be informed of the right to consult with a lawyer and have the lawyer present during the interrogation. Although the warnings were not as clear as they could have been, they were sufficiently comprehensive and comprehensible when given a commonsense reading. The Court cited the standard warnings used by the FBI as “exemplary,” but declined to require that precise formulation to meet Miranda’s requirements.
On discretionary review of a unanimous decision of the Court of Appeals, ___ N.C. App. ___, 795 S.E.2d 625 (2017), in this first-degree murder case the court held that the defendant’s statements to officers were voluntary. The defendant voluntarily met with detectives at the police station in connection with a robbery and murder. He was questioned in an interview room for just under five hours before being placed under arrest and warned of his rights as required by Miranda. After being advised of his rights, the defendant signed a written waiver of those rights and made inculpatory statements. He was charged with first-degree felony murder. At trial he sought to suppress his statements to officers, arguing that he was subjected to custodial interrogation before being informed of his rights as required by Miranda, and that his inculpatory statements were made in response to improper statements by detectives inducing a hope that his confession would benefit him. The trial court denied his motion and he was convicted. On appeal the Court of Appeals concluded that the defendant’s inculpatory statements to law enforcement were given under the influence of fear or hope caused by the interrogating officers’ statements and actions and were therefore involuntarily made. The unanimous Court of Appeals panel held that the confession should have been suppressed but concluded the error was harmless beyond a reasonable doubt due to the overwhelming evidence of defendant’s guilt. The Supreme Court held that the Court of Appeals erred in condensing the Miranda and voluntariness inquiries into one; that the defendant did not preserve the argument that officers employed the “question first, warn later” technique to obtain his confession in violation of Miranda and Seibert; that the trial court’s conclusion that the requirements of Miranda were met is adequately supported by its findings of fact, as is its conclusion that defendant’s statements to officers were voluntarily made. The court thus modified and affirmed the decision of the Court of Appeals.
The trial court did not commit plain error by failing to exclude the defendant’s statements to investigating officers after his arrest. The defendant had argued that because of his limited command of English, the Miranda warnings were inadequate and he did not freely and voluntarily waive his Miranda rights. The court determined that there was ample evidence to support a conclusion that the defendant’s English skills sufficiently enabled him to understand the Miranda warnings that were read to him. Among other things, the court referenced the defendant’s ability to comply with an officer’s instructions and the fact that he wrote his confession in English. The court also concluded that the evidence was sufficient to permit a finding that the defendant’s command of English was sufficient to permit him to knowingly and intelligently waive his Miranda rights, referencing, among other things, his command of conversational English and the fact that he never asked for an interpreter.