Carroll v. State

After a jury trial, Defendant was found guilty of murder with the use of a deadly weapon and conspiracy to commit murder. The district court sentenced Defendant to life with the possibility of parole for the first-degree murder conviction. Defendant appealed, arguing, among other things, that the district court erred when it admitted Defendant’s inculpatory statements to detectives because he was not advised of his Miranda rights and was subject to an alleged custodial interrogation. The State, in response, claimed that Defendant spoke voluntarily with the police and, therefore, Miranda warnings were unnecessary. The Supreme Court affirmed, holding (1) the district court erred in denying Defendant’s motion to suppress because the police subjected him to a custodial interrogation without advising him of his Miranda rights, but the error was harmless; (2) the district court did not abuse its discretion by admitting recordings taken by Defendant, who wore a wire and spoke with others involved in the murder to corroborate his story; and (3) the State presented sufficient evidence to convicted Defendant of conspiracy and murder. View "Carroll v. State" on Justia Law