R.I. v. Innis

Case Summary

Procedural Posture

Petitioner, State of Rhode Island, appealed the judgment of the Supreme Court of Rhode Island, which set aside respondent's conviction for the kidnapping, robbery, and murder of a taxicab driver. The state supreme court found that respondent had been subjected to subtle coercion that was the equivalent of interrogation after respondent invoked his Miranda right to counsel.

Overview

Respondent was convicted of the kidnapping, robbery, and murder of a taxicab driver after the trial court denied respondent's motion to suppress the weapon and statements made by respondent to the police about the weapon. The state supreme court set aside respondent's conviction, finding that respondent had been subjected to subtle coercion that was the equivalent of interrogation after respondent invoked his Miranda right to counsel. On appeal, the court vacated the judgment of the state supreme court. The court held that the Miranda safeguards came into play whenever a person in custody was subjected to either express questioning or its functional equivalent. The court held that the term "interrogation" under Miranda referred not only to express questioning, but also to any words or actions on the part of the police that the police should know were reasonably likely to elicit an incriminating response from a suspect. The court held that respondent was not interrogated within the meaning of Miranda when the police officers voiced safety concerns about children finding the weapon from the crime and respondent interrupted them to say he would show them where the gun was located.

Outcome

The court vacated the judgment of the state supreme court that had set aside respondent's conviction for kidnapping, robbery, and murder. The court held that petitioner had not established that respondent's incriminating response was the product of words or actions on the part of the police that they should have known were reasonably likely to elicit an incriminating response.

LexisNexis^® Headnotes

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Custodial Interrogation

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > General Overview

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Self-Incrimination Privilege

Criminal Law & Procedure > Commencement of Criminal Proceedings > Interrogation > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Notice & Warning

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Self-Incrimination Privilege

Criminal Law & Procedure > Counsel > Right to Counsel > General Overview

Evidence > Privileges > Self-Incrimination Privilege > General Overview

HN1  Self-Incrimination Privilege, Custodial Interrogation

In the context of "custodial interrogation" certain procedural safeguards are necessary to protect a defendant's Fifth and Fourteenth Amendment privilege against compulsory self-incrimination. The prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. Those safeguards included the now familiar Miranda warnings-namely, that the defendant be informed that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires-or their equivalent.

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Right to Counsel During Questioning

Criminal Law & Procedure > Commencement of Criminal Proceedings > Interrogation > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Self-Incrimination Privilege

HN2  Self-Incrimination Privilege, Right to Counsel During Questioning

Once Miranda warnings have been given, the subsequent procedure is clear. If an individual states that he wants an attorney, the interrogation must cease until an attorney is present. At that time, the individual must have an opportunity to confer with the attorney and to have him present during any subsequent questioning. If the individual cannot obtain an attorney and he indicates that he wants one before speaking to police, they must respect his decision to remain silent.

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Custodial Interrogation

Criminal Law & Procedure > Commencement of Criminal Proceedings > Interrogation > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > General Overview

HN3  Self-Incrimination Privilege, Custodial Interrogation

Custodial interrogation is questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.