Jennings v. State
127 So. 3d 185
| Miss. | 2013Background
- Jennings was convicted of statutory rape and resisting arrest and sentenced to fifteen years, with ten to serve and five suspended, plus six months for resisting arrest.
- J.S., age 13, accused Jennings of rape; deputy attempted to question Jennings after he fled, arresting him for assaulting an officer.
- At the police station, detective Perrigin and Lt. Perkins interrogated Jennings; the interrogation was audio recorded and the Miranda warnings were read in a brief, rote manner.
- The Miranda waiver was signed after a rapid, minimally explanatory reading; Jennings did not affirm understanding of rights, and asked what an attorney was.
- The interrogation included coercive and leading remarks about telling the truth; three written statements were produced over about 70 minutes.
- The trial court overruled a suppression motion without findings; the Court of Appeals affirmed; the Mississippi Supreme Court granted certiorari to review the suppression ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Jennings's Miranda waiver voluntary, knowing, and intelligent? | Jennings contends waiver was involuntary. | State contends waiver was valid. | Waiver not proven; remand for proper showings. |
| Did the trial court err by failing to make adequate findings on voluntariness? | Jennings argues record lacks factual findings on voluntariness. | State argues the waiver was properly admitted. | Remand for a new suppression hearing with explicit voluntariness findings. |
Key Cases Cited
- Fare v. Michael C., 442 U.S. 707 (U.S. 1979) (totality of circumstances in voluntariness assessment)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (mandatory warnings and waiver framework)
- Spring v. Colorado, 479 U.S. 564 (U.S. 1987) (waiver must be voluntary, knowing, intelligent)
- McGowan v. State, 706 So.2d 231 (Miss. 1997) (juvenile considerations and capacity to understand warnings)
- Jackson v. Denno, 378 U.S. 368 (U.S. 1964) (due process review of voluntariness with reliability)
- Williams v. State, 115 So.3d 774 (Miss. 2013) (two-part test for voluntary waiver)
- Neal v. State, 451 So.2d 743 (Miss. 1984) (heavy burden to show knowing and intelligent waiver)
- Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (full awareness of rights and consequences)
- Pitchford v. State, 45 So.3d 216 (Miss. 2010) (due process review of voluntariness in confession)