Motion to suppress a statement to police; Right against self-incrimination; U.S. Const. amend. V; Const. 1963, art. 1, § 17; People v. Elliott; Whether a defendant’s waiver of his rights under Miranda v. Arizona was voluntary, knowing & intelligent; People v. Tierney; Whether a waiver was voluntary; People v. Daoud; People v. Givans; People v. Cipriano; People v. Fike; People v. Howard; People v. Cheatham

The court held that the trial court erred by granting the defendant’s motion to suppress his statement to police. He was arrested in connection with the armed robbery of a gas station. While in custody, he signed a Miranda waiver and confessed to his involvement in the crime. He was then charged with armed robbery and conspiracy to commit armed robbery. The trial court granted his motion to suppress the statement. The court remanded twice, but the trial court granted the motion each time. On appeal, the court found that the trial court erred in finding that defendant’s waiver was involuntary, noting it “improperly analyzed whether [his] statement was voluntary by failing to make a factual finding regarding whether the police coerced [him] into waiving his Miranda rights by exploiting his mental deficiencies.” It noted there was “no evidence” that any coercion occurred, and that “the majority of the Cipriano factors weighed heavily in favor of finding that defendant’s waiver was voluntary and defendant’s mental deficiencies, standing alone, were an insufficient basis on which to find” otherwise. The court also found that the trial court “improperly analyzed whether defendant’s waiver was knowing and intelligent by failing to consider the ‘total circumstances.’” It noted the trial court failed to consider certain “facts surrounding the interrogation or explain how the expert’s conclusions regarding defendant’s mental deficiencies were alone sufficient" to prevent defendant’s waiver from being knowing and intelligent. In addition, while the trial court found that the officer “did read defendant his Miranda rights, the trial court still concluded that he did not understand the rights.” Reversed and remanded to a different judge.