Thank You For Submiting Feedback!
The analysis of whether an interrogation has occurred for purposes of triggering Miranda protections focuses primarily upon the perceptions of the suspect, rather than the intent of the police. The focus on a suspect's perceptions reflects that the Miranda safeguards were designed to vest a suspect in custody with an added measure of protection against coercive police practices, without regard to objective proof of the underlying intent of the police. While the focus of the test is on the suspect's perceptions, the intent of a police officer is nonetheless relevant. The intent of the officer, particularly when a police practice is designed to elicit an incriminating response, may bear on the question of whether the police should have known that their words or actions were reasonably likely to evoke an incriminating response. Additionally, any knowledge the police may have had concerning the unusual susceptibility of a defendant to a particular form of persuasion might be an important factor in determining whether the police should have known that their words or actions were reasonably likely to elicit an incriminating response from the suspect.
Four eye witnesses identified Craig Brownlee as the person who car-jacked a vehicle and fled from the vehicle after he ran it into a pole. The identifications, however, were pursuant to a show-up procedure, whereby the witnesses were brought to the scene of the accident and shown Brownlee, who was sitting in the back of a police car. The district court denied Brownlee’s motion to suppress the identifications.
Did the District Court err by refusing to suppress incriminating statements Brownlee allegedly made to a police officer whom he knew at the time he was brought to the scene of the accident?
The court on review affirmed. While it found that the identifications were inherently suggestive, the totality of the circumstances established that the identifications were reliable, given the witnesses' accurate descriptions, that they viewed Brownlee in broad daylight, and that little time had passed since they had last seen him. However, the court went on to hold that it was wrong for the district court to have excluded expert testimony regarding the reliability of the very eyewitness identification evidence on which Brownlee was convicted. Additionally, the court concluded that a police officer subjected Brownlee to an interrogation without providing the warnings demanded by Miranda. Admission of Brownlee’s statements during that interrogation was not harmless error.