Bobby v. Dixon
132 S. Ct. 26
| SCOTUS | 2011Background
- Dixon and Hoffner murdered Hammer to steal his car; Dixon forged Hammer’s signature to cash a check and sold the car for $2,800.
- Hammer’s mother reported him missing; police investigated and encountered Dixon in a noncustodial, chance encounter on Nov. 4, 1993.
- Dixon was given Miranda warnings during a later forgery arrest interview; he confessed to forging Hammer’s name but denied involvement in the disappearance.
- Hoffner led police to Hammer’s grave; Dixon was then questioned again and gave a detailed confession to murder after Miranda warnings.
- Ohio courts suppressed Dixon’s unwarned forgery confession but admitted the later murder confession, applying Elstad to deem both confessions voluntary.
- The Sixth Circuit reversed the Ohio Supreme Court, alleging three errors: improper Miranda analysis, coercion concerns, and misapplication of Elstad.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the murder confession admissible under Elstad after unwarned confession? | Dixon | Houk/Ohio | No reversible federal error; confession admissible |
| Did the Miranda warnings against Dixon on Nov. 9 undermine the prior unwarned statements under Seibert? | Dixon | Houk/Ohio | Not contrary to clearly established law; Seibert not controlling |
| Did police coercion by urging a deal before Hoffner's statements violate the Fifth Amendment? | Dixon | Houk/Ohio | Not clearly established; no basis to overturn Ohio Supreme Court |
| Was Ohio Supreme Court's application of Elstad reasonable in distinguishing voluntary confessions? | Dixon | Houk/Ohio | Not contrary to clearly established federal law; Ohio decision sustained |
Key Cases Cited
- Elstad v. Oregon, 470 U.S. 298 (U.S. 1985) (two-stage interrogation; later warned confession admissible if voluntary)
- Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (two-step interrogation; second confession may be inadmissible)
- Mincey v. Arizona, 437 U.S. 385 (U.S. 1978) (continuous questioning at the edge of consciousness; coercion concerns)
- McNeil v. Wisconsin, 501 U.S. 171 (U.S. 1991) (no invocation of Miranda rights in noncustodial context)
- Montejo v. Louisiana, 556 U.S. 778 (U.S. 2009) (Miranda applicability in noncustodial settings clarified)