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Warden Berghuis v. Thompkins

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On June 1, 2010, the Supreme Court decided Berghuis v. Thompkins in a 5-4 vote (No. 08-1470 slip opinion). The Court ruled that suspects must explicitly invoke their Miranda protections during criminal interrogations. Justice John Kennedy delivered the opinion for the Court joined by Justice Roberts, Justice Scalia and Justice Alito. Justice Sonya Sotomayor authored the dissenting opinion joined by Justice Stevens and Justice Breyer.


Contents

Procedural history

Thompkins was charged with first-degree murder, assault with intent to commit murder, and certain fire-arms-related offenses. He moved to suppress the statements made during the interrogation. The jury found Thompkins guilty on all counts. He was sentenced to life in prison without parole.[1]

Thompkins's appellate counsel filed a motion for a new trial which was rejected by the trial court. Thompkins appealed this ruling to the Michigan Court of Appeals, along with the trial court's refusal to suppress his pretrial statements under Miranda. Michigan Court of Appeals rejected the Miranda claim, ruling that he failed to invoke his right to remain silent and thereby waived it. Michigan Supreme Court denied discretionary review.[2]

Thompkins filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Michigan. The District Court also rejected Thompkins's Miranda claim. The District Court upheld all the previous courts's rulings.[3]

The United States Court of Appeals for the Sixth Circuit reversed, holding for Thompkins on the Miranda claim. The Court opined that the state court unreasonably applied clearly established federal law and based its decision on an unreasonable determination of the facts.[4]

Facts

On January 10, 2000, a fatal shooting occurred outside a mall in Southfield, Michigan where Samuel Morris died from multiple gunshot wounds. Van Chester Thompkins was detained for questioning by two Southfield police officers. The custodial interrogation began around 1:30 p.m. and lasted about 3 hours. During this time, Respondent Thompkins sat on a chair resembling a school desk (it had an attached surface for writing purposes) in a room 8 by 10 feet.[5]

Detective Helgert presented the respondent with a form delineating the Miranda rights. When asked to sign the form, Thompkins refused to provide his signature. The taped evidence provides conflicting indications of whether Thompkins understood his rights. As the interrogation commenced and continued, Thompkins remained largely silent with limited utterances of "yeah," "no," or "I don't know."[6]

After 2 hours and 45 minutes of questioning, Detective Helgert asked, "Do you pray to God to forgive you for shooting that boy down?" The respondent answered "Yes" and looked away.[7]

Analysis

The Court held that a suspect who receives and understands Miranda warnings, and fails to invoke his Miranda rights, waives the right to remain silent when offering an uncoerced statement to the police. Thompkins did not invoke his right to remain silent and stop the questioning. When Thompkins said "Yes," he waived his right to remain silent by making a voluntary statement to the police.[8]

Moreover, the police were not required to obtain a waiver of Thompkins's right to remain silent prior to questioning him. Id.

Holding

The Michigan Court of Appeal's rejection of Thompkins's Miranda claim was thereby correct under de novo review.[9]

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References

  1. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  2. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  3. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  4. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  5. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  6. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  7. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  8. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf
  9. http://www.supremecourt.gov/opinions/09pdf/08-1470.pdf

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