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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The Sixth Circuit erroneously concluded that a prisoner is in custody within the meaning of Miranda if the prisoner is taken aside and questioned about events that occurred outside the prison. While incarcerated, Randall Fields was escorted by a corrections officer to a conference room where two...
The Court, per curiam, held that the Sixth Circuit erroneously concluded that a state supreme court ruling affirming the defendant’s murder conviction was contrary to or involved an unreasonable application of clearly established federal law. The defendant and an accomplice murdered the victim,...
In this North Carolina case, the Court held, in a five-to-four decision, that the age of a child subjected to police questioning is relevant to the Miranda custody analysis. J.D.B. was a 13-year-old, seventh-grade middle school student when he was removed from his classroom by a...
In this North Carolina case, the Court held, in a five-to-four decision, that the age of a child subjected to police questioning is relevant to the Miranda custody analysis. J.D.B. was a 13-year-old, seventh-grade middle school student when he was removed from his classroom by a...
The defendant was arrested in connection with a shooting that left one victim dead and another injured. At the start of their interrogation of the defendant, officers presented him with a written notification of his constitutional rights, which contained Miranda warnings. During the...
The defendant was arrested in connection with a shooting that left one victim dead and another injured. At the start of their interrogation of the defendant, officers presented him with a written notification of his constitutional rights, which contained Miranda warnings. During the...
The Court held that a 2½ year break in custody ended the presumption of involuntariness established in Edwards v. Arizona, 451 U.S. 477 (1981) (when a defendant invokes the right to have counsel present during a custodial interrogation, a valid waiver of that right cannot be established...
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...
The defendant was arrested for murder, waived his Miranda rights, and gave statements in response to officers’ interrogation. He was brought before a judge for a preliminary hearing, who ordered that the defendant be held without bond and appointed counsel to represent him. Later that...
The defendant’s incriminating statement to a jailhouse informant, obtained in violation of the defendant's Sixth Amendment right to counsel, was admissible on rebuttal to impeach the defendant’s trial testimony that conflicted with statement. The statement would not have been admissible during...
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...
On discretionary review of a unanimous decision of the Court of Appeals, ___ N.C. App. ___, 803 S.E.2d 33 (2017), the court reversed, holding that the trial court’s order denying the defendant’s motion to suppress contained sufficient findings of fact to support its conclusion that the defendant...
Because the defendant was in custody while confined under a civil commitment order, the failure of the police to advise him of his Miranda rights rendered inadmissible his incriminating statements made during the interrogation. On December 10, 2012, a Stephanie Gaddy was robbed. On...
Applying Berghuis v. Thompkins, 560 U.S. 370 (2010),the court held that the defendant understood his Miranda rights and through a course of conduct indicating waiver, provided a knowing and voluntary waiver of those rights. During the interrogation, the defendant never said...
Applying Berghuis v. Thompkins, 560 U.S. 370 (2010),the court held that the defendant understood his Miranda rights and through a course of conduct indicating waiver, provided a knowing and voluntary waiver of those rights. During the interrogation, the defendant never said...
Reversing the Court of Appeals, the court held that the juvenile defendant’s request to telephone his mother while undergoing custodial questioning by police investigators was not a clear indication of his right to consult with a parent or guardian before proceeding with the questioning. The...
The court rejected the defendant’s argument that by telling officers that he did not want to snitch on anyone and declining to reveal the name of his accomplice, the defendant invoked his right to remain silent requiring that all interrogation cease.
A capital defendant was not in custody when he admitted that he stabbed the victim. Considering the totality of the circumstances, the defendant is an adult with prior criminal justice system experience; the officer who first approached the defendant told him that he was being detained until...
In this McDowell Countyt case of first impression, the Court of Appeals determined that law enforcement officers were not required to provide the defendant with Miranda warnings while he barricaded himself in a bedroom for many hours and threatened to commit suicide while officers...
In this Randolph County case, the defendant appealed from his conviction for statutory rape, arguing that the trial court erred in (1) denying his motion to suppress evidence from his interrogation because he requested and did not receive counsel, and (2) denying his motion to dismiss because...
This Lee county case has a lengthy procedural history, summarized in State v. Benitez, 258 N.C. App. 491, 813 S.E.2d 268 (2018) (Benitez I). Most recently, the case was remanded to the trial court to conduct a review of the totality of the...
The defendant was accused of killing his aunt in Lenoir County. Following his arrest, the defendant initially requested an attorney and was not interrogated, but later contacted detectives and signed a Miranda waiver. The defendant offered to make a full statement if he could see his...
The defendant was convicted of first-degree murder, robbery with a dangerous weapon, and assault with a deadly weapon with the intent to kill inflicting serious injury. He was sentenced to life without parole for the murder conviction and to shorter terms for the other convictions. The...
Considering the circumstances under which Miranda warnings are required when a member of the Armed Forces is questioned by a superior officer about involvement in the commission of a crime, the court concluded that the trial court’s order denying the defendant’s motion to suppress statements to...
The trial court did not err by denying the defendant’s motion to suppress incriminating statements made to police during a custodial interview. The defendant asserted that the statements were made after he invoked his right to counsel. Before the custodial interview, the defendant was advised of...
(1) In this case involving a gang-related home invasion and murder, the court remanded to the trial court on the issue of whether the defendant’s waiver of his right to counsel was voluntary. Officers interrogated the 15-year-old defendant four times over an eight hour period. Although he...
(1) On an appeal from an adverse ruling on the defendant’s motion for appropriate relief (MAR) in this murder case, the court held that because the defendant’s attorney made an objectively reasonable determination that the defendant’s uncle would qualify as his “guardian” under G.S. 7B-2101(b)...
The trial court did not err by denying the defendant’s motion to suppress statements made to an officer while the officer was transporting the defendant to the law enforcement center. It was undisputed that the defendant made the inculpatory statements while in custody and before he had been...
In this impaired driving case, the court rejected the defendant’s argument that the trial court erred by denying his motion to suppress self-incriminating statements made without Miranda warnings, finding that the defendant was not in custody at the time. The standard for determining...
In this child sexual assault case, the court rejected the defendant’s argument that his confession was obtained in violation of Miranda. During an interview at the sheriff’s department, the defendant admitted that he had sex with the victim. The transcript and videotape of the interview...
The court rejected the defendant’s claim that counsel was ineffective by failing to object to the admission of his statement to an officer that the cocaine in question belonged to him and not a passenger in the vehicle; the court rejected the defendant’s argument that the statements were...
In this robbery case, the court rejected the defendant’s argument that the trial court erred by denying his motion to suppress statements to a police officer during an interrogation outside of the presence of his parent. Notwithstanding an issue about how the Juvenile Waiver of Rights Form was...
Although the defendant was in handcuffs at the time of the questioning, he was not, based on the totality of the circumstances, “in custody” for purposes of Miranda. While the defendant was visiting his cousin’s house, a parole officer arrived to search of the cousin’s home. The parole...
(1) The defendant was not in custody when he gave statements to officers at the hospital. The victim was killed in a robbery perpetrated by the defendant and his accomplice. The defendant was shot during the incident and brought to the hospital. He sought to suppress statements made to police...
(1) Because the defendant was handcuffed and placed under arrest, the trial court erred by concluding that the defendant was not in custody when he made a statement to the officer. (2) The defendant was subject to an interrogation when, after handcuffing the defendant, placing him under arrest,...
(1) Because the defendant was handcuffed and placed under arrest, the trial court erred by concluding that the defendant was not in custody when he made a statement to the officer. (2) The defendant was subject to an interrogation when, after handcuffing the defendant, placing him under arrest,...
The defendant’s statements, made during the stop were voluntary and not the result of any custodial interrogation. None of the officers asked or said anything to the defendant to elicit the statement in question. Rather, the defendant volunteered the statement in response to one officer...
On remand from the NC Supreme Court the court held, in this murder case, that the defendant’s Fifth Amendment rights were not violated. The defendant argued on appeal that the trial court erred in denying his motion to suppress because he invoked his Fifth Amendment right to counsel during a...
In a child sexual assault case, the trial court erred by finding that the defendant’s statements were made involuntarily. Although the court found that an officer made improper promises to the defendant, it held, based on the totality of the circumstances, that the statement was voluntarily....
The trial court did not err by finding that the defendant’s statements were given freely and voluntarily. The court rejected the defendant’s argument that they were coerced by fear and hope. The court held that an officer’s promise that the defendant would “walk out” of the interview regardless...
The court rejected the defendant’s argument that she was in custody within the meaning of Miranda during an interview at the police station about her missing child. The trial court properly used an objective test to determine whether the interview was custodial. Furthermore competent...
Rejecting the defendant’s argument that that “[t]he detectives’ lies, deceptions, and implantation of fear and hope established a coercive atmosphere”, the court relied on the trial court’s findings of fact and found that the defendant’s statement was voluntary.
The defendant’s statements, made while a police officer who responded to a domestic violence scene questioned the defendant’s girlfriend, were spontaneous and in not response to interrogation. The State conceded that the defendant was in custody at the time. The court rejected the defendant’s...
No prejudicial error occurred when the trial court denied the defendant’s motion to suppress statements made by him while being transported in a camera-equipped police vehicle. After being read his Miranda rights, the defendant invoked his right to counsel. He made the statements at...
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...
The court rejected the State’s argument that the defendant initiated contact with the police following his initial request for counsel and thus waived his right to counsel. After the defendant asserted his right to counsel, the police returned him to the interrogation room and again asked if he...
The court rejected the State’s argument that the defendant initiated contact with the police following his initial request for counsel and thus waived his right to counsel. After the defendant asserted his right to counsel, the police returned him to the interrogation room and again asked if he...
The trial court did not err by finding the defendant’s statements to his wife voluntary. The defendant’s wife spoke with him five times while he was in prison and while wearing a recording device provided by the police. The wife did not threaten defendant but did make up evidence which she...
The trial court did not err by denying a fourteen-year-old juvenile’s motion to suppress his oral admissions to investigating officers. The motion asserted that the juvenile was in custody and had not been advised of his rights under Miranda and G.S. 7B-2101. The court found that the...
A thirteen-year-old juvenile was not in custody within the meaning of G.S. 7B-2101 or Miranda during a roadside questioning by an officer. Responding to a report of a vehicle accident, the officer saw the wrecked vehicle, which had crashed into a utility pole, and three people walking...
A thirteen-year-old juvenile was not in custody within the meaning of G.S. 7B-2101 or Miranda during a roadside questioning by an officer. Responding to a report of a vehicle accident, the officer saw the wrecked vehicle, which had crashed into a utility pole, and three people walking...
The court rejected the juvenile’s argument that his statement was involuntary. The juvenile had argued that because G.S. 20-166(c) required him to provide his name and other information to the nearest officer, his admission to driving the vehicle was involuntary. The court rejected this argument...
The rule of State v. Walker, 269 N.C. 135 (1967) (State may not introduce evidence of a written confession unless that written statement bears certain indicia of voluntariness and accuracy) does not apply where an officer testified to the defendant’s oral statements.
After waiving his right to counsel the defendant did not unambiguously ask to speak a lawyer. The court rejected the defendant’s argument that he made a clear request for counsel. It concluded: “Defendant never expressed a clear desire to speak with an attorney. Rather, he appears to have been...
The defendant’s confession was voluntary. The court rejected the defendant’s argument that he “was cajoled and harassed by the officers into making statements that were not voluntary,” that the detectives “put words in his mouth on occasion,” and “bamboozled [him] into speaking against his...
(1) After being read his Miranda rights, the defendant knowingly and intelligently waived his right to counsel. The court rejected the defendant’s argument that the fact that he never signed the waiver of rights form established that that no waiver occurred. The court also rejected the...
In this child sexual abuse case, the defendant’s confession was not involuntary. After briefly speaking to the defendant at his home about the complaint, an officer asked the defendant to come to the police station to answer questions. The court rejected the defendant’s argument that his...
Citing Berkemer v. McCarty, 468 U.S. 420, 442 (1984), the court held that the defendant was not in custody for purposes of Miranda during a traffic stop.
The defendant’s waiver of Miranda rights was knowing, voluntary, and intelligent. Among other things, the defendant was familiar with the criminal justice system, no threats or promises were made to him before he agreed to talk, and the defendant was not deprived of any necessaries....
The juvenile defendant was not in custody for purposes of Miranda. After the defendant had been identified as a possible suspect in several breaking or entering cases, two detectives dressed in plain clothes and driving an unmarked vehicle went to the defendant’s home and asked to speak...
The court rejected the defendant’s argument that his confession was improperly obtained after he invoked his right to counsel. Although the defendant invoked his right to counsel before making the statements at issue, because he re-initiated the conversation with police, his right to counsel was...
The court rejected the defendant’s argument that his confession was involuntary because it was obtained through police threats. Although the defendant argued that the police threatened to imprison his father unless he confessed, the trial court’s findings of fact were more than sufficient to...
The trial court did not err by denying the defendant’s motion to suppress three statements made while he was in the hospital. The defendant had argued that medication he received rendered the statements involuntary. Based on testimony of the detective who did the interview, hospital records, and...
The court rejected the defendant’s argument that his Fifth Amendment right to remain silent was violated where there was ample evidence to support the trial court’s finding that the defendant did not invoke that right. The defendant had argued that his refusal to talk to police about the crimes...
The defendant’s response to the officer’s questioning while on the ground and being restrained with handcuffs should have been suppressed because the defendant had not been given Miranda warnings. The officer’s questioning constituted an interrogation and a reasonable person in the...
The defendant was not in custody when he made a statement to detectives. The defendant rode with the detectives to the police station voluntarily, without being frisked or handcuffed. He was told at least three times — once in the car, once while entering the police station, and once at the...
The defendant was not in custody when he confessed to three homicides. Officers approached the defendant as he was walking on the road, confirmed his identity and that he was okay, told him that three people had been injured at his residence, and asked him if he knew anything about the situation...
A reasonable person in the defendant’s position would not have believed that he or she was under arrest or restrained in such a way as to necessitate Miranda warnings. Key factors in the Miranda custody determination include: whether a suspect is told he or she is free to leave...
The trial court did not err by denying the defendant’s motion to suppress statements made during a police interrogation where no violation of G.S. 7B-2101 occurred. The defendant, a 17-year-old juvenile, was already in custody on unrelated charges at the time he was brought to an interview room...
No violation of the defendant’s sixth amendment right to counsel occurred when detectives interviewed him on new charges when he was in custody on other unrelated charges. The sixth amendment right to counsel is offense specific and had not attached for the new crimes.
The trial court did not err by denying the defendant’s motion to suppress asserting that his interrogation was not electronically recorded in compliance with G.S. 15A-211. The statute applies to interrogations occurring on or after March 1, 2008; the interrogation at issue occurred more than one...
The court rejected the defendant’s argument that because he was under the influence of cocaine he did not knowingly, intelligently, and understandingly waive his Miranda rights or make a statement to the police. Because the defendant was not under the influence of any impairing...
The trial court properly suppressed the defendant’s confession on grounds that it was involuntary. Although the defendant received Miranda warnings, interviewing officers, during a custodial interrogation, suggested that the defendant was involved in an ongoing murder investigation,...
Citing Berghuis v. Thompkins, 560 U.S. 370 (2010), the court held that the defendant’s silence or refusal to answer the officers’ questions was not an invocation of the right to remain silent.
The trial court erred by denying a juvenile’s motion to suppress when the juvenile’s confession was made in the course of custodial interrogation but without the warnings required by Miranda and G.S. 7B-2101(a), and without being apprised of and afforded his right to have a parent...
The trial court did not err by denying the defendant’s motion to suppress where, although the defendant initially invoked his Miranda right to counsel during a custodial interrogation, he later reinitiated conversation with the officer. The defendant was not under the influence of...
The defendant’s waiver of Miranda rights was valid where Miranda warnings were given by an officer who was not fluent in Spanish. The officer communicated effectively with the defendant in Spanish, notwithstanding the lack of fluency. The defendant gave clear, logical, and...
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...
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...
A juvenile’s statement, made while in custody, was the product interrogation and not a voluntary, spontaneous statement. The trial court thus erred by denying the juvenile’s motion to suppress the statement, since the juvenile had not advised her of her rights under Miranda and G.S. 7B-...
A SBI Agent’s testimony at the suppression hearing supported the trial court’s finding that the Agent advised the defendant of his Miranda rights, read each statement on the Miranda form and asked the defendant if he understood them, put check marks on the list by each...
The proper standard for determining whether a person was in custody for purposes of Miranda is not whether one would feel free to leave but whether there was indicia of formal arrest. On the facts presented, there was no indicia of arrest.
When the defendant asked, “Do I need an attorney?” the officer responded, “are you asking for one?” The defendant failed to respond and continued telling the officer about the shooting. The defendant did not unambiguously request a lawyer.
The trial judge properly determined that a juvenile’s statements, made after an officer’s search of his person revealed cash, were admissible. The juvenile’s stated that the cash was not from selling drugs and that it was his mother’s rent money. The statement was unsolicited and spontaneous.
Defendant’s mother was not acting as an agent of the police when, at the request of officers, she asked her son to tell the truth about his involvement in the crime. This occurred in a room at the police station, with officers present.
The defendant was subject to interrogation within the meaning of Miranda when he made incriminating statements to a detective. The detective should have known that his conduct was likely to elicit an incriminating response when, after telling the defendant that their conversation would...
The defendant was not in custody while being treated at a hospital. Case law suggests that the following factors should be considered when determining whether questioning in a hospital constitutes a custodial interrogation: whether the defendant was free to go; whether the defendant was coherent...
The trial court erred by denying the juvenile’s motion to suppress his incriminating statement where the juvenile’s waiver was not made “knowingly, willingly, and understandingly.” The juvenile was not properly advised of his right to have a parent, guardian, or custodian present during...
Officers did not interrogate the defendant within the meaning of Miranda. An officer asked the defendant to explain why he was hanging out of a window of a house that officers had approached on an informant’s tip that she bought marijuana there. The defendant responded, “Man, I’ve got...
The police did not impermissibly interrogate the defendant after he requested a lawyer by offering to allow him to speak with his grandmother by speaker phone. Once the defendant stated that he wished to have a lawyer, all interrogation ceased. However, before leaving for the magistrate’s office...
The defendant’s statement, “I’m probably gonna have to have a lawyer,” was not an invocation of his right to counsel. The defendant had already expressed a desire to tell his side of the story and was asked to wait until they got to the station. Notwithstanding this, he gave a brief unsolicited...