133 So. 3d 359
Miss. Ct. App.2012Background
- Davis, convicted of armed robbery as a habitual offender, received life without parole.
- Arrested by Tennessee police after a car accident near Memphis.
- Interrogated for about 12 minutes in Memphis; Davis confessed to a Horne Lake, Mississippi robbery.
- Davis claimed intoxication and heroin use prior to arrest, and a recent head injury; suppression motion denied.
- Trial court reviewed voluntariness under totality-of-circumstances and credibility standard; finding supported by evidence.
- Court affirms conviction and admission of confession following voluntariness analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the confession involuntary under totality of circumstances? | Davis contends intoxication rendered confession involuntary. | State argues prima facie voluntariness proven; no violence or coercion shown. | Confession voluntary; trial court did not err. |
| Did the trial court properly apply admissibility standards for voluntariness? | State failed to acknowledge Davis’s intoxication impact. | Court properly weighed credibility and total circumstances. | Yes, admissible; no error in ruling. |
Key Cases Cited
- Pannell v. State, 7 So.3d 277 (Miss. Ct. App. 2008) (burden on State to show voluntariness; review standards)
- Glasper v. State, 914 So.2d 708 (Miss. 2005) (credible examination of voluntariness; standard of review)
- Marshall v. State, 812 So.2d 1068 (Miss. Ct. App. 2001) (totality-of-circumstances governs voluntariness)
- Greenlee v. State, 725 So.2d 816 (Miss. 1998) (source for voluntariness framework)
- Lott v. State, 844 So.2d 502 (Miss. App. 2003) (prima facie case; rebuttal by defendant)
- Cox v. State, 586 So.2d 761 (Miss. 1991) (establishing voluntariness standard)
- Kircher v. State, 758 So.2d 1017 (Miss. 1999) (intoxication evaluation in voluntariness)
- Johnson v. State, 511 So.2d 1360 (Miss. 1987) (intoxication and voluntariness considerations)
- United States v. Taylor, 508 F.2d 761 (5th Cir. 1975) (federal perspective on reliability; voluntariness)
- Crawford v. State, 716 So.2d 1028 (Miss. 1998) (credibility determinations in voluntariness analysis)