Francisco Garcia v. David Long, 2015 U.S. App. LEXIS 22205

Police brought Francisco Alaniz Garcia to the station to investigate allegations by his granddaughter of long‑term sexual abuse; Detective Beatty read Garcia his Miranda rights.
Beatty asked, “now having that in mind, do you wish to talk to me?” Garcia answered “No.” Officers continued questioning despite that answer; after some back‑and‑forth Garcia agreed to talk and ultimately admitted to three incidents and wrote an apology letter.
At trial the prosecution played the full 3 hour 45 minute interrogation recording and read the apology letter to the jury; Garcia did not testify and defense counsel conceded Garcia’s admissions on several counts while contesting the rape charge.
The jury convicted Garcia on all counts and he received 35 years to life. The California Court of Appeal held Garcia’s initial “no” was equivocal in context and that any error was harmless beyond a reasonable doubt; California Supreme Court denied review.
The federal district court granted Garcia habeas relief, finding the state court’s decision conflicted with Supreme Court Miranda precedents; the Ninth Circuit affirmed, concluding Garcia’s “no” was an unambiguous invocation of the right to remain silent and the admission was not harmless.

Issue	Plaintiff's Argument (Garcia)	Defendant's Argument (State)	Held
Whether Garcia’s one‑word “No” constituted an unambiguous invocation of the right to remain silent	“No” was a clear, unequivocal invocation; officers were required to cease questioning and could not use later statements to retroactively render the invocation ambiguous	The “no” was ambiguous in context: Garcia later explained he didn’t know the charges and earlier volunteered supplemental answers, so officers could clarify and continue	Held for Garcia: the initial “no” was unambiguous; Smith and Miranda bar using postrequest statements to cast doubt on a clear invocation, so questioning should have ceased
Whether admission of the interrogation tape and apology letter was harmless error	The tape and letter were highly prejudicial and central to prosecution’s case; their admission had a substantial and injurious effect on the verdict	The conviction would stand on Jane Doe’s testimony and other properly admitted evidence; any error was harmless beyond a reasonable doubt	Held for Garcia: error was not harmless under Brecht; the recorded confession was focal to prosecution closing and substantially influenced the jury

Miranda v. Arizona, 384 U.S. 436 (right to be warned and to cut off questioning when invoking Miranda rights)
Smith v. Illinois, 469 U.S. 91 (per curiam) (postrequest statements cannot be used to cast retrospective doubt on an unambiguous request for counsel)
Davis v. United States, 512 U.S. 452 (clarifies that only unambiguous invocations require cessation; uses an objective test)
Berghuis v. Thompkins, 560 U.S. 370 (applies Davis standard to right to remain silent; unambiguous assertions cut off questioning)
Brecht v. Abrahamson, 507 U.S. 619 (habeas harmless‑error standard: substantial and injurious effect)
Arizona v. Fulminante, 499 U.S. 279 (a confession can be the most damaging evidence; courts must be cautious in finding such error harmless)