State v. Martin, 228 N.C. App. 687 (Aug. 6, 2013)

The defendant’s confession was involuntary. The defendant’s first confession was made before Miranda warnings were given. The officer then gave the defendant Miranda warnings and had the defendant repeat his confession. The trial court suppressed the defendant’s pre-Miranda confession but deemed the post-Miranda confession admissible. The court disagreed, concluding that the circumstances and tactics used by the officer to induce the first confession must be imputed to the post-Miranda confession. The court found the first confession involuntary, noting that the defendant was in custody, the officer made misrepresentations and/or deceptive statements, the officer made promises to induce the confession, and the defendant may have had an impaired mental condition.