and SC14-826 State of Florida v. Michael Lindsey McAdams and Michael Lindsey McAdams v. State of Florida
193 So. 3d 824
| Fla. | 2016Background
- Pasco detective conducted welfare check at estranged wife Lynda McAdams’ home and observed blood, blood-stained clothing, latex gloves, duct tape, and a bullet hole; Pasco contacted Michael McAdams, who consented to a search.
- Separate Spring Hill residence yielded blood-stained shorts and other items; deputies executed a search warrant and seized clothing.
- Michael McAdams voluntarily went to Hernando County Sheriff’s Office to speak with detectives; interview was recorded, he was told he was not under arrest, and an attorney retained by his parents arrived but was denied access and the attorney left.
- During a one-on-one segment with Detective Arey, McAdams confessed before receiving Miranda warnings; detectives later gave Miranda and continued questioning, then McAdams directed police to the bodies.
- Trial court denied motions to suppress; McAdams was convicted of two counts of first-degree murder. The Second District reversed in part and certified a question of great public importance regarding whether a noncustodial interview subject must be informed that retained counsel is present at the station.
- Florida Supreme Court held (1) under Florida’s due process clause police must notify a person in a non-public interview when an attorney retained on the person’s behalf is present and wishes to consult, regardless of custody status; (2) McAdams’ interview became custodial before his confession and admission of the confession was a Miranda violation that was not harmless.
Issues
| Issue | McAdams’ Argument | State’s Argument | Held |
|---|---|---|---|
| Must police notify a person questioned in a non-public area that an attorney retained on their behalf is present and wishes to speak? | Yes — due process under Fla. Const. art. I, §9 requires notification regardless of custody so defendant can choose counsel. | No — absent outrageous misconduct, no duty to inform in noncustodial settings; due process only requires action in custody or extreme cases. | Held: Police must notify the person in a non-public interview that retained counsel is present and available, regardless of custodial status. |
| Whether McAdams was in custody (triggering Miranda) when he confessed | McAdams: the interview became custodial due to accusatory tactics, presentation of strong evidence, restricted restroom escort, and statements implying he could not leave. | State: He came voluntarily, was told he was not under arrest, rode voluntarily, and was not physically restrained. | Held: Totality of circumstances shows McAdams was in custody before his 2:27 p.m. confession; Miranda warnings were required earlier. |
| Whether failure to notify counsel and pre‑Miranda confession required suppression and reversal | McAdams: both Haliburton due-process violation and Miranda violation required suppression of confession and derived evidence. | State: Even if error, suppression not required absent outrageous conduct; harmless-error or other doctrines could apply. | Held: Both the due-process failure to inform and the Miranda violation rendered the confession inadmissible; the Miranda error was not harmless beyond a reasonable doubt, requiring reversal. |
| Scope of Haliburton (limited to custodial settings or broader) | McAdams: Haliburton’s protection should apply regardless of custody to prevent police from denying access to retained counsel in isolated, non-public interviews. | State: Haliburton should be confined to custodial interrogations; extending it to voluntary interviews is unnecessary and disrupts law enforcement practice. | Held: Haliburton protection is extended: law enforcement must notify a person in a non-public interview when retained counsel is present; custody is irrelevant to that specific due-process notification duty. |
Key Cases Cited
- Haliburton v. State, 476 So.2d 192 (Fla. 1985) (original Haliburton facts and holding regarding counsel contact)
- Haliburton v. State, 514 So.2d 1088 (Fla. 1987) (Haliburton II) (Florida due process requires notifying a custodial suspect when privately retained counsel is at the station)
- Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (U.S. Supreme Court held that failure to inform suspect of outside events does not violate Fifth Amendment waiver rules but left open state-law protections)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires warnings to protect Fifth Amendment rights)
- Ross v. State, 45 So.3d 403 (Fla. 2010) (confrontation with strong forensic evidence can convert a voluntary interview into custodial interrogation)
- Ramirez v. State, 739 So.2d 568 (Fla. 1999) (framework/factors for determining custody in Florida)
- Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (statements taken in violation of Miranda may require exclusion; custodial statements are subject to suppression)
- State v. DiGuilio, 491 So.2d 1129 (Fla. 1986) (harmless-error test for constitutional violations)