Darnell Smith v. Commonwealth of Kentucky
520 S.W.3d 340
| Ky. | 2017Background
- Darnell Smith was tried for three separate January 2014 robberies in downtown Louisville (Kingsolving, Worthington, Pino) and convicted on multiple counts; total sentence 25 years.
- Police linked Smith to the incidents via surveillance footage, victim identifications, and Smith’s own statements; he blamed an unidentified companion for much of the conduct.
- While jailed for the Pino robbery, Smith was visited by Detective Matt Ditch on March 7; Smith refused to speak and asked for a lawyer.
- On April 3 (almost a month later) Detective Ditch returned, read Miranda rights from a waiver form, Smith refused to sign the form without a lawyer but, after clarification, agreed to speak and made inculpatory statements; that recording was played at trial.
- Smith sought suppression of the April 3 statements, sought to introduce evidence of his prior refusal to sign the waiver form, objected to admission of a black hooded sweatshirt found among his jail property, and moved to sever the three robberies; the trial court denied suppression, excluded the refusal-to-sign evidence, admitted the sweatshirt, and denied severance.
Issues
| Issue | Smith's Argument | Commonwealth's Argument | Held |
|---|---|---|---|
| 1. Admissibility of April 3 statements under Miranda/Edwards | March 7 invocation of counsel barred later questioning; April 3 statements were product of impermissible post-invocation questioning | March 7 invocation had lapsed (not "custody" for Miranda or >14-day noncustodial period), and on April 3 Smith did not clearly request counsel and thus waived | Court affirmed: Smith did not unambiguously invoke counsel on April 3; waiver was valid and statements admissible |
| 2. Excluding evidence that Smith refused to sign waiver form | Exclusion prevented jury from seeing circumstances of his April 3 statements and impaired right to present a defense | The refusal-to-sign relates to suppression (legal issue) not credibility; it would improperly invite antipolice sentiment and has little probative value on voluntariness | Court affirmed exclusion as within trial court’s discretion; evidence not necessary to assess credibility/voluntariness |
| 3. Admission of black hooded sweatshirt found in jail property | Sweatshirt was unrelated (from 2011) and unduly prejudicial because witnesses described a dark hoodie; should be excluded as irrelevant/unduly prejudicial | Commonwealth offered the item but could not prove a connection; even if error, admission was harmless given overwhelming other evidence | Court held sweatshirt admission was error but harmless beyond a reasonable doubt; conviction stands |
| 4. Denial of motion to sever the three robberies (joinder) | Joinder allowed spillover prejudice; severance required to avoid undue prejudice | Offenses were of same/similar character and joinder appropriate; evidence for each offense strong so little risk of undue prejudice | Court affirmed: joinder proper and, in any event, no showing of actual undue prejudice given strong admissible evidence for each offense |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required before custodial interrogation)
- Edwards v. Arizona, 451 U.S. 477 (1981) (suspect’s clear request for counsel bars further questioning until counsel present)
- Rhode Island v. Innis, 446 U.S. 291 (1980) (Miranda protected interrogation requirement)
- North Carolina v. Butler, 441 U.S. 369 (1979) (waiver of Miranda rights may be found from the suspect’s actions and words)
- Minnick v. Mississippi, 498 U.S. 146 (1990) (after request for counsel, only suspect may reinitiate communication)
- Maryland v. Shatzer, 559 U.S. 98 (2010) (14-day rule for expiration of Edwards protection when suspect returns to general population)
- Davis v. United States, 512 U.S. 452 (1994) (invocation of the right to counsel must be unambiguous)
- Howes v. Fields, 565 U.S. 499 (2012) (incarceration alone does not automatically establish Miranda custody)
- Montejo v. Louisiana, 556 U.S. 778 (2009) (discussion of waiver and counsel rules in post-invocation contexts)
- Crane v. Kentucky, 476 U.S. 683 (1986) (defendant’s right to present a complete defense where circumstances producing a confession are highly relevant)