New York Criminal Attorney Blog
During interrogation, New York detectives and officers are only legally able to obtain statements from defendants that are made voluntarily. If a detective coerces a defendant, or if the defendant does not understand what he or she is being interrogated about, a court may later rule that any confession was involuntarily and thus invalid. A recent case coming out of the Appellate Division, Third Department, shows some of the limits on this law and serves as a reminder of the importance of experienced, qualified counsel in criminal cases.
The Ruling
In the court’s ruling, it first reiterated the law that when prosecuting a criminal case, the State bears the burden of showing that a defendant’s statements during interrogation were voluntary. The State must therefore show that the defendant’s statements were “not products of coercion, either physical or psychological.”
In the case before the court, a defendant was being interrogated about a recent murder. During the interrogation, the defendant asked the questioning officer for medical attention, and the officer refused. Later on in the conversation, the defendant confessed to being involved in the murder, and he ended up pleading guilty to manslaughter in the first degree. Before pleading guilty, however, he filed a motion to suppress the confession, which the trial court denied.
Appealing the denial of the motion to suppress, the defendant argued that the officer unreasonably denied him access to medical care. He said that because he did not receive the care he needed, his statement was involuntary and therefore invalid. To decide whether it agreed with the defendant, the court reviewed the video tape of the defendant’s confession.
During the confession, noted the court in its opinion, the defendant appeared withdrawn and uncomfortable, but he did not seem to require medical attention. The court therefore agreed with the prosecution, that his request for medical care was illegitimate. It subsequently denied the defendant’s appeal.
The court’s opinion serves as a reminder that there are limits on how case law interprets the definition of “voluntary.” While a court does not want defendants to make statements under coercion, it will also not necessarily deem a statement involuntary just because the defendant states he or she needs medical attention. Overall, the case also serves a reminder that retaining aggressive counsel is important from the very beginning of a case. When in doubt, don’t hesitate to ask for an attorney, and don’t hesitate to search for a legal team that is experienced and that promises to have your back.
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