Thank You For Submiting Feedback!
Standard conditions of confinement and associated restrictions on freedom will not necessarily implicate the same interests that the Court sought to protect when it afforded special safeguards to persons subjected to custodial interrogation. Thus, service of a term of imprisonment, without more, is not enough to constitute Miranda custody.
Defendant Ronald Grant Champney was arrested and placed in prison on unrelated arson charges. During this time, defendant made incriminating statements regarding a homicide case. Defendant filed a motion to suppress the statements he made to the police officers. The trial court concluded that Champney unambiguously invoked his right to counsel during an interview with police on December 23, 1997 and that, as a result, the statements he made the next May were obtained in violation of his rights under Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966) and Edwards v. Arizona, 451 U.S. 477, 101 S. Ct. 1880, 68 L. Ed. 2d 378 (1981). The Commonwealth appealed.
Did the trial court properly grant defendant’s motion to suppress statements made to police?
The granting of defendant's motion to suppress statements made to police was improper because, while he successfully invoked his right to counsel, there was a sufficient break in custody between the invocation and the later questioning to permit the police to question him again after obtaining a proper waiver of his Miranda rights. While defendant invoked his right to counsel on December 23, 1997, there was a sufficient break in custody between then and May 13, 1998 that his May 13, 1998 statements were not subject to the Edwards presumption, and his Miranda waiver was valid.