Hartman v. State
2012 Ind. App. LEXIS 82
Ind. Ct. App.2012Background
- Hartman, incarcerated for burglary, was interviewed Feb. 22, 2010; Miranda rights were given and he asked to speak with a specific attorney, ending the interview.
- The next day, warrants were executed on Hartman’s property; father’s dead body was found.
- Detective Pullins read the warrants to Hartman at the jail, asked if he had questions, and Hartman indicated he wanted to speak with them.
- Hartman then waived rights and provided an incriminating statement about his involvement in his father’s death.
- Hartman was charged with Murder and assisting suicide; he moved to suppress the statement, which the trial court denied.
- On appeal, Hartman challenges the denial of suppression, arguing re-interrogation occurred after he invoked, and he did not initiate further discussion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the denial of suppression was correct | Hartman argues officers re-interrogated after counsel invocation | State contends Hartman initiated the further discussion | Affirmed; Hartman initiated further discussion and waived rights |
Key Cases Cited
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel halts interrogation until counsel available)
- Owens v. State, 732 N.E.2d 161 (Ind.2000) (initiation/waiver analysis after counsel invocation)
- Smith v. Illinois, 469 U.S. 91 (U.S. 1984) (preponderance of evidence standard for initiation after counsel invocation)
- White v. State, 772 N.E.2d 408 (Ind.2002) (Miranda interrogation scope includes functional equivalent)
- Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (standard for what constitutes interrogation)
- Faris v. State, 901 N.E.2d 1123 (Ind.Ct.App.2009) (standard for reviewing suppression denials)
- S.D. v. State, 937 N.E.2d 425 (Ind.Ct.App.2010) (definition of interrogation under Indiana law)