Jalonte Little v. United States
125 A.3d 1119
| D.C. | 2015Background
- Jolonta Little, 18, was interrogated about a September 19, 2008 carjacking; the interrogation was videotaped and lasted over five hours with the confession occurring about two hours in.
- Little was shackled in a small room; detectives read Miranda rights and offered a deal to explain or alibi, while pressuring him to talk.
- Detectives falsely claimed evidence (fingerprints, witness identifications) and suggested enhanced penalties for an unrelated offense to coerce cooperation.
- Detectives repeatedly implied that meeting with Little’s attorney would occur only after he confessed, conditioning legal access on confession, and threatened consequences to induce cooperation.
- The trial court denied suppression; on appeal, the court held the confession involuntary and remanded for a new trial, reversing the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the confession voluntary under totality of the circumstances? | Little | Little’s waiver/voluntariness valid | No; confession involuntary; remand for new trial |
| Was the Miranda waiver voluntary given coercive interrogation? | Little | Waiver valid after warnings | No; coercive tactics tainted waiver; reversal warranted |
| Did the detectives’ handling of counsel access violate invocation rights? | Little | Counsel right not clearly invoked | No; coercive conditions persisted regardless of invocation |
| Did coercive tactics, including threat of sexual assault, render the confession involuntary? | Little | Tactics within permissible coercion spectrum | Yes; coercive conduct rendered confession involuntary; remand for new trial with exclusion of the confession |
Key Cases Cited
- Haynes v. Washington, 373 U.S. 503 (Supreme Court 1963) (due-process coercion standard for confessions)
- In re J.F., 987 A.2d 1168 (D.C. 2010) (totality-of-circumstances voluntariness evaluation)
- Turner v. United States, 761 A.2d 845 (D.C. 2000) (voluntariness test for statements)
- United States v. Fulminante, 499 U.S. 279 (Supreme Court 1991) (coercive strategies and due process limits on confessions)
- Brisbon v. United States, 957 A.2d 931 (D.C. 2008) (premises for coercive interrogation analysis; extrinsic consequences)
- Dorsey v. United States, 60 A.3d 1171 (D.C. 2013) (deceptive police conduct and coercion scrutiny)
- In re J.F., 987 A.2d 1177 (D.C. 2010) (denials prior to confession as factor in voluntariness)
- Stewart v. United States, 668 A.2d 857 (D.C. 1995) (invocation and understanding of rights)
- Lynumn v. Illinois, 372 U.S. 528 (Supreme Court 1963) (coercive threats outside the courtroom context)
- Payne v. Arkansas, 356 U.S. 560 (Supreme Court 1958) (promise to protect from mob influence rendering confession involuntary)