Law School Case Brief
People v. Thomas - 2014 NY Slip Op 1208, 22 N.Y.3d 629, 985 N.Y.S.2d 193, 8 N.E.3d 308
It is the People's burden to prove beyond a reasonable doubt that statements of a defendant they intend to rely upon at trial are voluntary. To do that, they must show that the statements were not products of coercion, either physical or psychological, or, in other words that they were given as a result of a "free and unconstrained choice by their maker." The task is the same where deception is employed in the service of psychologically oriented interrogation; the statements must be proved, under the totality of the circumstances—necessarily including any potentially actuating deception—the product of the maker's own choice.
On the morning of Sept. 21, 2008, defendant Adrian P. Thomas' wife, Wilhelmina Hicks, awoke to discover that the couple's four-month-old, prematurely born infant, M.T., was limp and unresponsive. Emergency assistance was immediately summoned and the child was rushed to Samaritan Hospital in Troy, New York. There, he presented with a range of symptoms, including a low white blood cell count, irregular heartbeat, low blood pressure, severe dehydration and respiratory failure. The diagnosis was septic shock. M.T. was transferred to the Pediatric Intensive Care Unit at Albany Medical Center, where he continued to be treated for sepsis. The child's treating physician concluded that he had been a victim of blunt force trauma—indeed, that the by-then moribund child had been "murdered." Local child protective and law enforcement authorities were informed on the evening of Sept. 21st. Thomas was convicted for the murder M.T. in New York state court. The evidence considered by the jury included a statement in which he admitted that on three occasions during the week preceding M.T.'s death he "slammed" M.T. down on a mattress just 17 inches above the floor. The jury also saw a videotape of Thomas' interrogation, near the end of which Thomas, a particularly large individual, demonstrated how he raised the infant above his head and threw him down with great force on the low-lying mattress. The jury also heard testimony from the child's treating doctors from Albany Medical Center, the medical examiner who performed the autopsy, and an expert on child abuse from Brown Medical School. These witnesses, citing radiologic and postmortem findings of subdural fluid collections, brain swelling and retinal hemorrhaging, as well as Thomas' account of what he had done, said that M.T. died from intracranial injuries caused by abusively inflicted head trauma. Thomas argued at trial and on appeal that the proof before the jury was insufficient to support a verdict finding him guilty of depraved indifference murder. The appellate court affirmed the conviction of murder in the second degree. Thomas appealed.
Was the conviction proper?
The state's highest court held that although the evidence was sufficient to support the conviction depraved indifference murder, the court erred in considering Thomas' inculpatory written and videotaped statements. The court held that Thomas' motion to suppress those written and videotaped statements should have been granted because they were not demonstrably voluntary for purposes of U.S. Const. amend. V and XIV, based on the highly coercive deceptions used by the interrogators that included threats and false representations. These statements were also inadmissible as "involuntarily made" within the meaning of CPL 60.45(2)(b)(i) because the misrepresentations and false assurances used to elicit Thomas' admissions manifestly raised a substantial risk of false incrimination. Thus, the court reversed the order of the appellate division affirming Thomas' conviction, granted Thomas' previously denied motion to suppress, and directed a new trial.
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