Statements Made In Police Custody Are Not Admissible In Court If Made As A Result Of Threats
People v Aveni
22 NY Slip Op 01209
Court of Appeals
Decided on February 20, 2014
A Statement Made By Someone In Police Custody Is Not Voluntary If The Police Are Lying And Threatening The Accused In Order To Obtain The Statement.
Summary: Defendant’s girlfriend died of a heroin overdose and he was taken into custody to be questioned regarding her death. Upon interrogation, the Police lied to Defendant telling him that his girlfriend was alive. The Police coerced the Defendant by asking if his girlfriend had used any drugs. The Police implied that if the Defendant did not speak to them that he would be charged with her murder. The Defendant made a confession and was charged with her murder and the confession played an important role at trial.
Issue: Whether the confession was involuntary because the Police lied to Defendant and threatened him with Murder charges and overbore his ability to make a voluntary statement.
Holding: Whether a confession is voluntary in the due process sense is addressed to the totality of circumstances under which the statement was obtained. A voluntariness determination ordinarily implicates a mixture of factual and legal elements. Defendant could be held for his girlfriends demise if he did not immediately break his silence. The false prospect of being severely penalized for remaining silent, raised by Defendant’s interrogators, was, in the court’s view, incompatible with a finding that Defendant’s confession was voluntary beyond a reasonable doubt.
Facts: Police and emergency medical employees arrived at Defendant’s mother’s house. They found Defendant’s girlfriend, Angela Camillo, dead of an apparent heroin overdose. Defendant appeared from an attic space and was immediately arrested for violating a temporary order of protection. He was taken into custody and Police interrogators lied to Defendant about whether his girlfriend was alive. The Police made a veiled threat that he would be charged with her murder if he did not speak to the Police. Defendant then made an involuntary confession and admitted he had given his girlfriend heroin and injected her with it. This played a major role at his trial and Defendant was subsequently convicted of Murder.
Legal Analysis: The judicial inquiry as to whether a confession was voluntary is whether the totality of the circumstances under which the statement was obtained is valid. People v Guilford 21 NY3d 205. The Court Of Appeals noted that the Police interrogation and threats overwhelmed the Defendants free will and violated his rights. The Police coerced Defendant by lying and saying she was dead and they threatened him with charges of murder. As a result, Defendant made a statement confessing to injecting her with heroin because of Police threats. Accordingly, the Defendant’s statements were involuntary and inadmissible.