Admissibility of defendant’s police statements; Whether defendant was “interrogated” for Miranda purposes; People v Anderson; Harmless error; Sufficiency of the evidence for a first-degree murder conviction; Premeditation & deliberation; People v Oros; Jury instruction on voluntary manslaughter; People v Yeager; People v Pouncey

The court held that defendant was not “interrogated” for Miranda purposes when he made the statements at issue, and that there was sufficient evidence to support his first-degree murder conviction. It also concluded that a rational view of the evidence did not support a voluntary manslaughter jury instruction and thus, the trial court did not err in denying his request for the instruction. He was also convicted of unlawful imprisonment and felony-firearm. After committing the crimes, he “entered Lake Michigan, ostensibly to drown himself.” Police in dive boats that happened to be in the water for dive team training went to his location. He argued that he “was the subject of a custodial interrogation while treading water in Lake Michigan; therefore, his statements made to officers while he was in the water should have been suppressed because he had not been given his Miranda warnings beforehand.” He also asserted that this Miranda violation tainted his later statements made in an ambulance and at the police station. The court disagreed. As to his statements made while in the water, it was clear “that the sole focus of the police officers’ communications with defendant was on safely coaxing [him] out of the cold water and preventing him from committing suicide. [They] did not expressly question defendant as in a standard interrogation, nor did they engage in any effort to employ words or actions reasonably likely to elicit incriminating responses.” As to his statements made in the ambulance, he plainly volunteered them “without prompting from the accompanying officer.” The court added that, “even if there were Miranda violations in relation to” his statements, “they were harmless beyond a reasonable doubt.” The surviving victim’s “testimony, defendant’s Mirandized statements made at the police station, and [his] own trial testimony largely tracked the un-Mirandized statements regarding the events that occurred before, during, and after the homicide and overwhelmingly established the crime of first-degree premeditated murder.” As to his sufficiency of the evidence challenge, the court found “there was more than sufficient evidence to establish the elements of premeditation and deliberation.” Affirmed.