Benjamin v. State, 116 So. 3d 115

Benjamin was convicted of capital murder with robbery and sentenced to life without parole.
Police arrested Benjamin and questioned him after he invoked his right to counsel.
His mother interacted with him during interrogation; officers allowed the mother to influence him.
Benjamin gave a statement claiming he was at the county fair; this aligned with an alibi later used by co‑defendant witnesses.
The trial court denied suppression of the statement; on appeal, the court considers whether the Miranda waiver was valid.
This Court reverses and remands for a new trial, finding Miranda violations occurred after invocation of the right to counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Benjamin's statement obtained in violation of Miranda?	Benjamin contends interrogation resumed after invoking counsel; mother acted as police agent.	State contends waiver was knowing, intelligent, and voluntary; no Edwards violation.	Yes; statement obtained in violation of Miranda and Edwards; reversed and remanded.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requires rights advisement before custodial interrogation)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (once right to counsel invoked, interrogation must cease unless counsel is present or initiate further contact)
Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (defines interrogation to include functional equivalents of questioning)
Maryland v. Shatzer, 559 U.S. 98 (U.S. 2010) (presumption of involuntariness for waiver after invocation; limits on reinterrogation)
Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (knowingly and intelligently waives rights with full awareness of rights/consequences)
Arizona v. Mauro, 481 U.S. 520 (U.S. 1987) (private third-party contact not equivalent to interrogation when no coercive manipulation shown)