Commonwealth v. Yandamuri, 159 A.3d 503

Background

On October 22, 2012, Raghunandan Yandamuri entered the Vennas’ apartment, attempted to kidnap ten‑month‑old Saanvi for ransom, fatally stabbed the grandmother during a struggle, and later abandoned the baby who was recovered dead in a sauna; Yandamuri later confessed in written and video statements.
Detectives encountered Yandamuri at a casino three days after the crime; he accompanied them voluntarily to the police station, where he gave multiple statements over many hours, consented to searches, and waived Miranda before his final inculpatory confession.
Yandamuri moved to suppress statements and consents on multiple grounds (illegal arrest/detention at the casino, custodial interrogation without Miranda, involuntariness/coercion, and related Brady/false‑testimony claims); the suppression court denied relief after multiple hearings.
Yandamuri proceeded pro se at trial, was convicted of two counts of first‑degree murder and related offenses, and a jury recommended death for both murders; the trial court imposed two death sentences.
On automatic direct appeal, the Pennsylvania Supreme Court independently reviewed sufficiency and then rejected all suppression and related claims, concluding the statements were not the product of an illegal arrest, were not custodial prior to the Miranda warning, and were voluntary under the totality of the circumstances.

Issues

Issue	Appellant's Argument	Commonwealth's Argument	Held
Was the initial casino encounter an illegal arrest/deprivation of liberty?	Casino encounter was coercive (escorted by security, held phone/keys, could not freely leave) so arrest occurred and statements should be suppressed as fruit of poisonous tree.	Encounter was consensual — Yandamuri voluntarily agreed to go to station; no badges/weapons displayed; he was free to leave; not arrested at casino.	Encounter was a non‑custodial, consensual encounter; no illegal arrest — suppression denied.
Were pre‑11:03 p.m. statements inadmissible for lack of Miranda warnings?	Long stationhouse interrogation and practical restraints (keys/phone/no exit) made it custodial; statements before warnings should be suppressed.	Yandamuri was repeatedly told he was free to leave, took breaks, was offered food/restroom; statements were gratuitous and noncustodial.	Totality supports noncustodial interaction; Miranda not required before 11:03 p.m.; statements admissible.
Was the 11:03 p.m. Miranda advisal preceded by an illegal arrest, tainting later confession?	He was effectively under arrest at 11:03 p.m.; any subsequent confession was product of illegal seizure and should be suppressed (Dunaway attenuation).	Even after Miranda, he remained noncustodial until he voluntarily confessed; no illegal arrest occurred at 11:03 p.m.
Held	No illegal arrest at 11:03 p.m.; confession followed valid Miranda waiver and was not extinguished by any Fourth Amendment violation.
Was the ultimate confession involuntary/coerced?	Interrogation was prolonged (~13–16 hours), emotionally coercive (swearing on Bible, displaying baby photos, threats about wife, promises of breakfast), and Yandamuri was psychologically compromised.	Tactics did not overbear will; defendant highly educated, repeatedly told he was free to leave, signed waivers, reviewed statements, and appeared calm on video; voluntariness established by preponderance.	Court found, on suppression‑record credibility, confession voluntary under the totality of the circumstances; suppression denied.
Were suppression‑hearing factfindings false/Brady violations/prosecutorial misconduct?	Detective testimony contradicted trial testimony and records; prosecution knowingly presented false evidence and withheld exculpatory material.	Discrepancies do not prove knowingly false testimony; no specific withheld material identified; issues waived or unsupported.	No Brady showing or proof of deliberate false testimony; discrepancies insufficient to overturn suppression rulings.
Jury instruction on delay between arrest and arraignment (optional language)	Trial court erred by refusing optional instruction directing jury to consider delay in arraignment when assessing voluntariness.	No relevant delay claim — defendant was not arrested until after confession; instruction unnecessary and could confuse jury.	Instruction properly omitted because defendant's confession preceded arrest; no undue post‑arrest delay claim for jury to decide.

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (Miranda rights required before custodial interrogation)
Wong Sun v. United States, 371 U.S. 471 (fruit of the poisonous tree doctrine)
J.D.B. v. North Carolina, 564 U.S. 261 (custody inquiry objective; whether reasonable person would feel free to leave)
Stansbury v. California, 511 U.S. 318 (officer’s unexpressed subjective beliefs irrelevant to custody analysis)
Dunaway v. New York, 442 U.S. 200 (illegal arrest may taint subsequent statements unless attenuation shown)
Schneckloth v. Bustamonte, 412 U.S. 218 (voluntariness of consent judged under totality of circumstances)
Commonwealth v. Perez, 577 Pa. 360 (totality approach to voluntariness; delay to arraignment is a factor)
Commonwealth v. Poplawski, 130 A.3d 697 (circumstantial evidence sufficient; appellate standards)
Commonwealth v. Woodard, 129 A.3d 480 (standards for independent review of sufficiency and suppression rulings)