People v. Raper: Court of Appeals Rules on “Interrogation” in Custodial Interrogation
In the case of People v. Raper, the Court of Appeals discusses the interrogation aspect of custodial interrogation as it relates to Miranda warnings.
The Defendant in this case was convicted at a jury trial of first degree murder, carjacking, and possession of a firearm during the commission of a felony.
The Defendant was arrested in Muskegon for an alleged crime in Monroe County. After he was arrested, Monroe detectives picked him up from Muskegon and transported back to the east side of the state. During the car ride in the police vehicle, the Defendant confessed to a murder and carjacking. No Miranda warning were given during the car ride.
After his conviction, Defendant argues that his confession in the back of the police car was the result of a custodial interrogation, and he was no read his Miranda. Defendant had filed a motion to suppress these statements in the trial. The judge twice denied the motion. The judge stated that the Defendant’s statements were voluntary and spontaneous, and did not occur during an interrogation.
Miranda warnings must be read to a defendant who is the subject of a custodial interrogation. There’s two parts to that. The defendant must be in custody and subject to interrogation. The statements will be inadmissible in a trial if no Miranda warning were given.
The Court of Appeal’s Ruling
The Court ruled there was no question the Defendant was in custody at the time statements were made. The Court stated, “Because the defendant was handcuffed in the backseat of a moving police car when he made his inculpatory statement, there is little question that he was in custody when it was made.”
The Court agreed with the trial court that no interrogation took place. Under the law, interrogation means express questioning and any words or actions by police that police should know are reasonably likely to elicit an incriminating response from the subject.
In the trial court, the police detective testified the officers were merely conversing with Defendant when Defendant made incriminating statements.
The Court found the Defendant’s statements were not made in response to an interrogation, therefore he was not deprived of his Miranda rights.
The Court upheld the trial court’s decision.
Sam Bernstein is an Ann Arbor criminal defense lawyer.
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