Jeffrey Curry v. Paul Klee
17-1422
| 6th Cir. | Dec 19, 2017Background
- Curry shot Dedrick Jackson and was arrested after a chase that left him with minor injuries; officers took him to the station where he asked to go to the hospital.
- At the station Curry initially made pre-Miranda statements suggesting he acted in self-defense; detectives then read Miranda rights and he waived, making additional post-warning admissions.
- Curry moved to suppress his statements as involuntary, arguing detectives coerced him by refusing immediate medical care and that intoxication/sleep deprivation rendered him incapable of a voluntary waiver.
- The trial court denied suppression; Curry was convicted of second-degree murder and sentenced to 25–50 years. Michigan courts affirmed after an evidentiary hearing that found his waiver voluntary.
- On federal habeas review, the district court denied relief; the Sixth Circuit reviews de novo whether the state courts’ decision was contrary to or an unreasonable application of Supreme Court precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether detectives coerced Curry by delaying medical care to force a confession | Detectives refused to take him to hospital until he explained, constituting coercive police conduct making statements involuntary | Trial court found injuries minor and detectives credible that Curry could stop talking and was not denied care to force statements | State-court factual findings presumed correct; no clear & convincing evidence of coercion; voluntariness upheld |
| Whether intoxication/sleep-deprivation made waiver involuntary | Curry was drunk, high, and sleep-deprived, so he could not knowingly waive Miranda | Trial court found Curry alert and not intoxicated; no controlling Supreme Court precedent showing these facts made waiver involuntary | No clearly established law shown; state-court findings supported voluntariness |
| Admissibility of statements made before Miranda warnings | Pre-warning statements should be excluded because warnings came late and interrogation was coercive | State concedes pre-warning statements should not have been admitted but argues post-warning statements are admissible and pre-warning remarks were cumulative | Post-warning statements were admissible; pre-warning statements were largely cumulative and did not warrant habeas relief |
| Whether Seibert’s continuity rule made post-warning statements inadmissible on habeas review | Seibert plurality requires exclusion when interrogation is a deliberate two-step to elicit post-warning confession without effective waiver | Seibert plurality is not binding for habeas review; Elstad governs admissibility absent coercion | Sixth Circuit held Seibert does not create a binding rule for habeas review; state court’s admission of post-warning statements was not an unreasonable application of Supreme Court precedent |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings and waiver requirement)
- Colorado v. Connelly, 479 U.S. 157 (coercive police conduct is necessary predicate for involuntariness claim)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference: unreasonable application means no fairminded jurists could agree)
- Oregon v. Elstad, 470 U.S. 298 (post-warning statements admissible if waiver voluntary despite pre-warning admissions)
- Missouri v. Seibert, 542 U.S. 600 (plurality addressing deliberate two-step interrogation to evade Miranda)
- United States v. Ray, 803 F.3d 244 (6th Cir. decision that Seibert plurality is not binding for habeas review)
- Ruelas v. Wolfenbarger, 580 F.3d 403 (pre-warning statement error may be harmless if cumulative)