Com. v. Henderson, E., 819 MDA 2024

Evelyn Henderson was convicted by jury of second-degree murder and two arson-related offenses in connection with the death of her husband, whose burned body was discovered on their home's back porch.
Police responded after Henderson called 911; her responses to police were inconsistent about the event timeline, and her demeanor was described as aloof and unemotional.
At the police station and later at the county prison, Henderson gave conflicting stories but ultimately confessed to setting her husband on fire following renewed interrogation after the autopsy.
Henderson signed Miranda waivers prior to interviews, both at the station and in prison, expressly agreeing to speak without counsel present.
She was sentenced to life without parole for murder; arson counts merged for sentencing.
On appeal, she claimed her waiver of counsel was invalid, so her confession and statements should have been suppressed.

Issue	Henderson's Argument	Commonwealth's Argument	Held
Validity of Right to Counsel Waiver	Waiver invalid—she had invoked right to counsel by requesting a public defender, so police should have stopped questioning	No unequivocal invocation—her inquiry about a public defender was not a clear request for counsel; waiver was knowing and voluntary	Waiver valid—no clear invocation, Miranda waivers sufficient, statements admissible
Suppression of Statement to Police	Statements should be suppressed as fruit of an invalid waiver/counsel deprivation	Statements admissible as waiver was proper and police complied with legal standards	Suppression denied—statements legally obtained under valid waiver
Merger of Arson Counts for Sentencing	Possible illegality if arson convictions didn’t merge with murder count	Merger occurred—trial court explicitly merged arson counts for sentencing	No error—record shows proper merger, sentence legal

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishing right to counsel during custodial interrogation and Miranda warnings)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (once right to counsel is invoked, further interrogation must cease until counsel provided)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (ambiguous statements do not require police to stop questioning; clear invocation required)
McNeil v. Wisconsin, 501 U.S. 171 (U.S. 1991) (Sixth Amendment right to counsel attaches at initiation of adversarial proceedings, not before)