State v. Johnson

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The Supreme Court modified and affirmed the decision of the Court of Appeals concluding that Defendant’s inculpatory statements to law enforcement should have been suppressed but that the error was harmless, holding that the trial court correctly concluded that, under the totality of the circumstances, Defendant’s inculpatory statements were voluntary. On appeal, the Court of Appeals determined that Defendant’s inculpatory statements were involuntary and inadmissible because they were given under the influence of fear or hope caused by the interrogating officers’ statements and actions but that the admission of the statements was harmless beyond a reasonable doubt due to the overwhelming additional evidence of Defendant’s guilt. The Supreme Court modified and affirmed, holding (1) the trial court erred in merging the Miranda and voluntariness inquiries; (2) Defendant did not preserve his argument that officers employed the “question first, warn later” technique to obtain Defendant’s confession; and (3) the trial court correctly concluded that the Miranda requirements were met and that Defendant’s statements to the officers were voluntarily made. View "State v. Johnson" on Justia Law