The Fifth and Fourteenth Amendments to the U.S. Constitution grant persons accused of crimes the right to remain silent in the face of police questioning. The landmark U.S. Supreme Court case of Miranda vs. Arizona has defined this constitutional right by requiring police to give an in-custody suspect Miranda warnings before questioning them about alleged criminal activity. Miranda warnings instruct suspects that they do not need to answer any police questions and that any responses they give can be used as evidence against them if they face criminal charges. The law concerning a suspect’s Miranda rights is not always cut and dry, however, and statements given after a valid Miranda warning still may be inadmissible under some circumstances. The Arizona Court of Appeals recently ruled on an appeal filed by a defendant who alleged that statements he made to police after he was given his Miranda warnings should not have been admitted at his attempted murder trial.
The defendant from the recently decided appeal was stopped by police for his alleged involvement in a shootout with police that had occurred earlier in the day of his arrest. The defendant was injured with a gunshot wound at the time of his arrest and he was taken to the hospital for treatment under police supervision. According to the facts discussed in the appellate opinion, the defendant engaged in “small talk” with the police officers while he was at the hospital before he was given any Miranda warnings, and he made incriminating statements.
After the defendant’s condition was stabilized and he was released from the hospital, he was placed under arrest for attempted murder. After his arrest, the defendant was questioned by another officer, who read him his Miranda rights. During this second round of questioning, the defendant made more incriminating statements. At trial, the defiant challenged the admission of both rounds of statements. The trial court suppressed the first round of statements but admitted the second round because the defendant had been read his Miranda rights before making them. A jury ultimately convicted the defendant of attempted murder.