State v. Johnson, 371 N.C. 870 (Dec. 21, 2018)

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.

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