In re Darryl P., 63 A.3d 1142

Appellant Darryl P., a seventeen-year-old, was rearrested on May 6, 2011 after bail from February 23, 2011, on charges arising from a January 6, 2011 incident; indictment on April 6, 2011 added new charges; arrest warrants issued February 16, 2011 and April 15, 2011, with jurisdiction thereafter waived to juvenile court; suppression hearing on November 17, 2011 addressed inculpatory statements; appellant argued the May 6 interrogation was the fruit of an unlawful rearrest and violated multiple constitutional rights; court held the exclusionary rule framework is narrow and that Maryland has no independent exclusionary rule beyond Mapp v. Ohio; opinion emphasizes care in applying different constitutional doctrines separately and in watertight compartments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the confession must be suppressed as fruit of a poisonou s tree	Darryl P. argues rearrest on bail violated procedures.	State contends no Fourth Amendment violation; Mapp does not apply to state sub-constitutional rules.	No suppression under Mapp; no sub-constitutional exclusionary rule applies.
Whether Edwards v. Arizona prohibits interrogation after request for counsel	Edwards barred police interrogation after invoking counsel.	Edwards does not apply because no valid invocation occurred.	Edwards inapplicable; no Edwards violation.
Whether the May 6 interrogation violated Miranda and how waiver was shown	Interrogation violated Miranda; waiver was not clearly demonstrated.	Miranda warnings were given; waiver supported by conduct consistent with waiver.	Miranda rights satisfied; waiver supported; no violation.
Whether the confession was involuntary under Maryland common law	Confession induced by coercion	Voluntariness supported by totality of circumstances	Voluntariness satisfied under Maryland common law.
Whether the Sixth Amendment right to counsel was violated during interrogation	Appellant retained counsel; interrogation without counsel violated Massiah/Ch allenges.	Waiver valid; Patterson/Montejo analysis controls; concessive waiver.	Sixth Amendment right not validly waived; confession suppressed.

Mapp v. Ohio, 367 U.S. 643 ((1961)) (Exclusionary Rule applies to Fourth Amendment violations in state trials)
Virginia v. Moore, 553 U.S. 164 ((2008)) (State arrest statutes vs Fourth Amendment; sub-constitutional status of state law)
Davis v. United States, 512 U.S. 452 ((1994)) (Ambiguity in invoking right to counsel requires unambiguous request)
Berghuis v. Thompkins, 560 U.S. 370 ((2010)) (Waiver of Miranda rights can be inferred from conduct after warnings)
Patterson v. Illinois, 487 U.S. 285 ((1988)) (Miranda waiver not automatically equivalent to Sixth Amendment waiver)
Michigan v. Jackson, 475 U.S. 625 ((1986)) ( Edwards-like protection imported to Sixth Amendment arraignment context (overruled by Montejo))
Montejo v. Louisiana, 556 U.S. 778 ((2009)) (Overruled Jackson’s Edwards-style rule for Sixth Amendment waivers)
Massiah v. United States, 377 U.S. 201 ((1964)) (Right to counsel during post-indictment interrogation; strategic elicitation prohibited)
Wong Sun v. United States, 371 U.S. 471 ((1963)) (Fruit of the poisonous tree concept for Fourth Amendment violations)
Brown v. Illinois, 422 U.S. 590 ((1975)) (Fourth Amendment violation applied to exclude a post-violation confession)
Massachusetts v. Sheppard, 468 U.S. 981 ((1984)) (Good faith/exclusionary rule related to Fourth Amendment)