Reyes v. Lewis

Petitioner, convicted of first degree murder, petitioned for a writ of habeas corpus on the ground, inter alia, that his state-court conviction rested on a confession obtained in violation of Missouri v. Seibert. The district court denied relief. The court held that, under Justice Kennedy’s concurrence, a postwarning statement must be suppressed if interrogating officers deliberately use the two-step interrogation technique that was used in Seibert, and if effective curative measures are not taken to ensure that the suspect genuinely understood the Miranda warnings. Under the circumstances of this case - where police interrogated petitioner, a fifteen-year-old, over the course of two days; where on the first day at the Riverside police station they conducted a two-hour unwarned interrogation; where on the second day at the San Bernardino sheriff’s station they obtained a confession during an unwarned interrogation following an unwarned polygraph test; and where they transported petitioner back to the Riverside police station and obtained a postwarning confession “clarifying” what he had stated at the sheriff’s station - a Seibert analysis was clearly required. Contrary to Seibert, the Court of Appeal did not conduct such an analysis. The Court of Appeal addressed, and treated as dispositive, the question whether petitioner’s postwarning statement was voluntary, which is precisely the question that is irrelevant under Seibert. Therefore, the court concluded that the decision was “contrary to . . . clearly established Federal law, as determined by the Supreme Court.” The court concluded that the officers in this case deliberately employed the two-step interrogation technique condemned in Seibert, and that the magistrate judge and the district court clearly erred in concluding otherwise. The court reversed and remanded with instructions to grant habeas relief. View "Reyes v. Lewis" on Justia Law

Posted in: Criminal Law

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