Com. v. Dixson, S.
Com. v. Dixson, S. No. 234 WDA 2015
| Pa. Super. Ct. | Jun 9, 2017Background
- Appellant Shilee Dixson was convicted after a nonjury trial of second-degree murder, robbery inflicting serious bodily injury, criminal conspiracy, and possession of firearm by a minor; sentences imposed accordingly.
- The victim, Malachi Urbini, was shot and killed during a May 8, 2011 robbery in an alley in McKees Rocks, resulting in death when a bullet pierced the heart.
- Dixson gave a post-arrest confession; he moved to suppress on grounds that at the time of confession he was a minor, could not speak with a parent or interested adult, and did not knowingly and intelligently waive Miranda rights.
- A suppression hearing (Sept. 9–10, 2014) featured detective testimony about arrest, custodial interrogation, a waiver form signed at 12:00 p.m., and a nine-minute recorded statement at 2:06 p.m.; Dixson was briefly left alone in an interrogation room and shackled to the floor.
- The trial court denied the motion to suppress, finding the waiver of Miranda rights voluntary, knowing, and intelligent; Dixson was tried September 29–30, 2014 and convicted as noted above.
- Dixson timely appealed; the trial court’s 1925(a) opinion and appellate briefing framed two suppression issues: Miranda waiver and cell-phone data consent; the appellate standard is limited to whether factual findings are supported and legal conclusions are correct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the Miranda waiver validly voluntary and intelligent? | Dixson contends waiver was not knowing, voluntary, or intelligent. | Commonwealth contends waiver was voluntary and intelligent under totality of circumstances. | Waiver valid; confession admissible. |
| Did the court err in denying suppression of cell-phone data? | Dixson argues the phone data should have been suppressed. | Commonwealth contends no error; evidence admissible. | Issue abandoned/waived on appeal. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 ((1966)) (requires warnings before custodial interrogation)
- In re K.Q.M., 873 A.2d 752 ((Pa. Super. 2005)) (Miranda applicability to juveniles; waiver considerations)
- Rhode Island v. Innis, 446 U.S. 291 ((1980)) (custodial interrogation triggers Miranda safeguards)
- Commonwealth v. Freeman, 128 A.3d 1231 ((Pa. Super. 2015)) (two-dimensional test for juvenile Miranda waiver)
- Commonwealth v. Crompton, 682 A.2d 286 ((Pa. 1996)) (standard for reviewing suppression rulings)
- Commonwealth v. Chambers, 598 A.2d 539 ((Pa. 1991)) (scope of suppression review; factual findings)
- In re V.C., 66 A.3d 341 ((Pa. Super. 2013)) (juvenile waiver considerations; totality of circumstances)
