Com. v. Stone, D.
Com. v. Stone, D. No. 1657 MDA 2016
Pa. Super. Ct.May 30, 2017Background
- Stone, a contract physician at SCI-Muncy, was brought to the prison security office on June 3, 2015 to give a staff statement about a PREA allegation; Pennsylvania State Police Trooper Wool later joined the interview.
- Stone was held in the facility and told he could not leave; he was interviewed for about an hour and twice indicated he wanted an attorney if he were to be accused.
- While the interview paused, Stone signed a PSP consent form and Wool searched Stone’s vehicle, discovering a shared notebook.
- After Wool’s arrival and the vehicle search, Stone provided additional oral and written statements without receiving Miranda warnings.
- Stone moved to suppress statements made after Wool’s arrival; the trial court granted suppression of those statements (and of the notebook; the Commonwealth did not appeal the notebook ruling).
- The Commonwealth appealed only the portion suppressing statements made after Wool arrived, arguing the statements were voluntary and not the product of custodial interrogation.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Stone) | Held |
|---|---|---|---|
| Whether statements given after Wool’s arrival were admissible despite no Miranda warnings | Statements were voluntary, spontaneous, not the product of custodial interrogation | Statements were made while in custody and flowed from ongoing custodial interrogation, so Miranda required | Court affirmed suppression: statements inadmissible because they were given in custody, closely tied to prior interrogation, and not spontaneous |
| Whether a break for a vehicle search ended custodial interrogation such that Miranda no longer applied | The search created an intervening pause; subsequent statements were volunteered | The search occurred while Stone remained detained and pressure continued; interrogation effectively continued | Court found the pause insufficient; totality shows interrogation context persisted |
| Whether cases like Yount/Myers compel admissibility here | These precedents show some volunteered statements in custody can be admissible | Stone distinguished those cases as factually dissimilar (prior interrogation, invoked counsel) | Court held those authorities inapplicable and relied on Simala and Miranda principles |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires Miranda warnings to admit statements)
- Commonwealth v. Yount, 314 A.2d 242 (Pa. 1974) (volunteered admissions at stationhouse not product of custodial interrogation)
- Commonwealth v. Myers, 392 A.2d 685 (Pa. 1978) (spontaneous volunteered statement outside interrogation admissible)
- Commonwealth v. Simala, 252 A.2d 575 (Pa. 1969) (custody plus conduct likely to evoke admission requires Miranda; admonition to ‘talk’ transformed silence into urged admission)
- Commonwealth v. Williams, 941 A.2d 14 (Pa. Super. 2008) (totality of circumstances controls whether Miranda warnings are required; volunteered statements are an exception)