720 S.E.2d 84
Va.2012Background
- Quarles and an 11-year-old accomplice KT planned to rob a woman near VCU and used a brick to strike her; KT provided evidence and led officers to the weapon and phone.
- The victim, Kimberly Johnson, identified the weapon and phone, and KT led police to Quarles’s location after KT’s family provided information.
- Detective Alston interrogated KT first, obtaining a full confession, then questioned Quarles and obtained a full confession from him; Quarles was arrested and charged with robbery and conspiracy.
- Before trial, Quarles moved to suppress the confession as a Miranda violation, asserting the police reinitiated interrogation after he invoked his right to counsel.
- At suppression, the circuit court found that Alston’s statements to Papeo after Quarles declined to speak did not reinitiate interrogation and that Quarles initiated the later confession.
- The Court of Appeals reversed, holding the police violated Miranda by reinitiating interrogation, but the Supreme Court of Virginia reversed that decision and reinstated the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Alston’s statements after Quarles invoked counsel amounted to interrogation under Miranda/Innis. | Commonwealth argues no reinitiation; otherwise, confession admissible. | Quarles contends statements were functionally equivalent to interrogation after invocation. | No reinitiation; statements not interrogation; suppression denied. |
Key Cases Cited
- Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (interrogation includes functional equivalent beyond express questions)
- Arizona v. Mauro, 481 U.S. 520 (U.S. 1987) (subtle compulsion acknowledged in interrogation analysis)
- McNeil v. Wisconsin, 501 U.S. 171 (U.S. 1991) (waiver cannot be compelled after invoking counsel)
- United States v. Payne, 954 F.2d 199 (4th Cir. 1992) (exposure to inculpating evidence not always interrogation)