New Mexico v. Filemon V.

The State of New Mexico appealed the suppression of two statements made by sixteen-year-old Filemon V. Filemon made the first statement to his probation officers. The New Mexico Supreme Court held that, absent a valid waiver, Section 32A-2-14(C) of the Delinquency Act of the Children’s Code precluded the admission of Filemon’s statement to his probation officers while in investigatory detention. The Court affirmed the district court’s order suppressing the use of the statement in a subsequent prosecution. The second contested statement was elicited by police officers at the Silver City Police Department. Filemon was at this point in custody, and entitled to be warned of his Miranda rights. At issue was whether the midstream Miranda warnings were sufficient to inform Filemon of his rights. The Supreme Court concluded the warnings were insufficient under Missouri v. Seibert, 542 U.S. 600 (2004). Because the statement was elicited in clear violation of the Fifth Amendment and Section 32A-2- 19 14, the district court’s suppression of the statement was affirmed. View "New Mexico v. Filemon V." on Justia Law