Defendant Voluntarily Waived Miranda Rights
Case: People v. Colley (Unpublished Opinion)
Motion to suppress statements during a video-recorded interrogation; Whether defendant’s waiver of his Fifth Amendment rights was knowing, intelligent, & voluntary; People v. Gipson; People v. Tierney
Holding that despite defendant’s disability, he was competent to waive his rights and speak to the police, the court affirmed. Defendant argued that the trial court improperly denied his motion to suppress his statements during a video-recorded interrogation and subsequently erred by allowing the prosecution to play the video for the jury. He asserted that the combination of his traumatic brain injury, prescribed psychotropic medicine, and intoxication from alcohol and marijuana “rendered him incapable of rendering a knowing and intelligent waiver of his Fifth Amendment rights.” However, he “exhibited more than the ‘very basic understanding of [his Miranda] rights’ necessary for his waiver to be considered knowing and intelligent.” Further, although he had been prescribed psychotropic medication, there was “no indication that he was in an altered state at the time of his interview.” His medical records “indicated that he did not suffer from psychosis or delusions.” And he portrayed himself “as alert and aware of his situation in the recorded interview.” There also was no indication that he was “still under the influence of alcohol or marijuana during the interrogation.” Thus, defendant did “not overcome the evidence that his Miranda waiver was knowing and intelligent.” The trial court also did not err in determining that his waiver was voluntary. Neither the detention nor his interrogation was so long as to be coercive. He was in custody for about 13 hours and “likely slept through the majority of that period.” The interrogation lasted 55 minutes. Thus, the court found no error in the trial court’s admission of defendant’s video-recorded statement against him.