State v. Knowlton

Facts

STATE V. KNOWLTON

34 A.3d 1139 (2012)

NATURE OF THE CASE: State (P) appealed the suppression of Knowlton's (D) statements to a drug agent.

FACTS: Campbell investigated the importation of methamphetamine and other drugs from Canada. Campbell received information that D was involved in a drug-trafficking operation. Campbell approached D at his place of work, told D that he needed to speak with him, and asked D to accompany him to the Caribou Police Department. D agreed and was put into an interview room. D was told that two other individuals had been identified in connection with illegal drug trafficking and that he had reason to believe that D was also involved. Campbell read D his Miranda rights, which D confirmed he understood. Shortly thereafter, D became upset and asked to speak to an attorney. Agent Campbell immediately terminated the interview; placed D under arrest for aggravated trafficking of scheduled drugs, a Class A crime; and told D that he could speak with the officers if he wished to do so after he had spoken with an attorney. Campbell took D to jail. They were just a couple of blocks away, and Campbell raised the issue of speaking with police by stating again that if after speaking with an attorney, D wanted to speak with police, that he should just let them know and he would make the arrangements. D waited a few moments and then said, 'You know, screw it. I want to talk.' Campbell asked if that meant that he was prepared to speak with him without an attorney present. D acknowledged that was what he meant. They proceeded to the MDEA offices, and Campbell prepared a written waiver of rights form. D indicated that he had previously invoked his right to counsel but that after speaking with his mother he had changed his mind and was prepared to speak with the officer without an attorney. D signed the waiver and then participated in an interview with Campbell. D made incriminating statements that are the subject of D's motion to suppress. Five hours passed from D invoking his right to counsel and his subsequent written waiver. D was continuously in police custody. At no time during this period did D confer with a lawyer. D was indicted and moved to suppress the statements he made during his interview at the MDEA office. The court concluded that it was Campbell who had initiated an exchange about interrogation with D, finding that D 'remained emotionally vulnerable'; that it was 'Campbell who first spoke of the issue after D had invoked his rights'; and that 'during the first forty-five minutes of the ride to Houlton, D had not 'initiated further communication, exchange, or conversation' about speaking with the police.' The motion was granted and P appealed. 

ISSUE: Is the question of whether a defendant has reinitiated an interrogation by the police without a break in custody to be answered by careful examination of all relevant facts and reasonable inferences that can be drawn?

RULE OF LAW: The question of whether a defendant has reinitiated an interrogation by the police without a break in custody is to be answered by careful examination of all relevant facts and reasonable inferences that can be drawn.

HOLDING AND DECISION: (Levy, J.) Is the question of whether a defendant has reinitiated an interrogation by the police without a break in custody to be answered by careful examination of all relevant facts and reasonable inferences that can be drawn? Yes. After a defendant invokes the right to counsel, he or she 'is not subject to further interrogation by the authorities until counsel has been made available, . . . unless the accused . . . initiates further communication, exchanges, or conversations with the police.' An accused who has 'expressed his desire to deal with the police only through counsel, is not subject to further interrogation by the authorities until counsel has been made available to him unless the accused' is the one who initiates further communication with the police. D's suppression motion rests on whether D initiated an interrogation by telling Campbell that he wanted to cooperate with the police but that he was scared. The question of whether D's statement initiated interrogation is ultimately a question of law. It can only be answered after a careful examination of all relevant facts and the reasonable inferences that can be drawn from them. Reversed and remanded. 

Dissenting: (Alexander, J.) Key to the trial court's finding on failure to prove voluntariness was its finding that it was 'difficult to know whether D truly had a change of heart or whether he remained subject to the inherently coercive and mounting pressures of his custodial circumstance when he signed the [Miranda] waiver.' When the defense raises a voluntariness issue regarding a statement, or, more precisely, a choice to make a statement, the State must prove voluntariness beyond a reasonable doubt. The trial court's finding that it is difficult to know what motivated D to speak is supported by the record, and a contrary finding is not compelled by the record.

LEGAL ANALYSIS: The rules are simple. Once D asks for an attorney, Police cannot reinitiate conversation about the case unless D voluntarily initiates. As always voluntariness is an amorphous concept dependent on the totality of the circumstances. 

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Issues

Rule of Law

Holding and Decision

Legal Analysis

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