DOLL, SCOTT F., PEOPLE v
KA 11-00150
| N.Y. App. Div. | Jul 6, 2012Background
- Genesee County Sheriff’s Deputies detained and questioned Doll without Miranda warnings while investigating blood evidence after a suspicious person call.
- Blood and clothing evidence suggested a victim was injured; victim’s body not yet found.
- Deputies sought to locate a possible victim and conducted extensive searches and interviews, including at Doll’s van and with his friends.
- Doll invoked his right to counsel; deputies continued questioning under the emergency doctrine to aid potential victims.
- Debate at suppression hearing: whether statements to police and to Doll’s friend were admissible and whether physical evidence and warrants were properly obtained.
- Trial led to a murder conviction; Doll challenged suppression rulings and various evidentiary issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the emergency doctrine justified continued questioning without miranda warnings | People: emergency aid justified due to potential victims | Doll: no victim known; emergency exception misapplied | Yes, emergency exception applied to permit questioning |
| Whether statements to Doll’s friend were admissible given lack of state actor involvement | People: statements independent of police were admissible | Doll: private actor did not implicate right to counsel | Admissible; private actor not acting as government agent; harmless error |
| Whether the detentions and seizures violated Fourth/Fifth Amendment protections | People: search/seizure and detentions justified by De Bour levels and emergent need | Doll: improper arrest/detention without probable cause | Detentions and seizure upheld under De Bour framework and emergency need |
| Whether the van and other physical evidence could be seized without warrant | People: probable cause and exigent circumstances existed | Doll: lack of standing and improper seizure | Seizure of van and related evidence upheld |
Key Cases Cited
- People v Mejia, 64 AD3d 1144 (4th Dept 2011) (custody and Miranda considerations under emergency circumstances)
- People v Rhodes, 49 AD3d 668 (4th Dept 2008) (custody determinations and questioning amid investigation)
- People v Yukl, 25 NY2d 585 (1969) (Miranda custody standards and police questioning)
- People v Kimes, 37 AD3d 1 (4th Dept 2007) (emergency/public safety doctrine allowing questioning after counsel request)
- Oquendo, 252 AD2d 312 (3d Dept 1998) (emergency aid exception to Miranda/5th Amendment)
- Quarles, 467 U.S. 649 (1984) (public safety exception to Miranda applicable to gun in public place)
- People v Zalevsky, 82 AD3d 1136 (4th Dept 2011) (emergency exception duration after victim discovery)