Brian Scott Hartman v. State of Indiana, 988 N.E.2d 785

Hartman charged with Murder and Assisting Suicide in Randolph County.
Hartman moved to suppress statements made to a detective after requesting counsel.
Detective questioned Hartman Feb. 22, 2010; Hartman invoked right to counsel, questioning ceased.
Next day, warrants were executed at Hartman’s residence; Hartman was later brought to intake and read warrants, then allowed to speak with detectives.
Hartman made incriminating statements after the warrants were read and questions were posed.
Trial court denied suppression; Court of Appeals affirmed; Indiana Supreme Court granted transfer and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did police reinitiate interrogation after counsel invocation?	Hartman	Hartman	Yes, improper interrogation after invocation.
Was the ensuing waiver knowing and intelligent under the totality of circumstances?	Hartman	Hartman	Waiver not knowing and intelligent; involuntary.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes right to counsel during custodial interrogation)
Edwards v. Arizona, 451 U.S. 477 (1981) (reinitiation after counsel request requires caution unless defendant initiates)
Rhode Island v. Innis, 446 U.S. 291 (1980) (defines interrogation and functional equivalent)
Maryland v. Shatzer, 559 U.S. 98 (2010) (limits on re-interrogation after release from custody)
Oregon v. Bradshaw, 462 U.S. 1039 (1983) (defines knowing and intelligent waiver standard)
Massey v. State, 473 N.E.2d 146 (1985) (totality of circumstances test for voluntariness)
Taylor v. State, 689 N.E.2d 699 (1997) (review of suppression rulings as sufficiency-like analysis)
Grimm v. State, 556 N.E.2d 1327 (1990) (coercion and voluntariness in waiver context noted)
United States v. Villapando, 588 F.3d 1124 (7th Cir. 2009) (police tactics and limits on interrogation after invocation)
Kontny, 238 F.3d 815 (7th Cir. 2001) (limits on interrogation tactics; substantive coercion concerns)