Jordan Diangelo Champion v. Commonwealth of Virginia, 1596161

On Nov. 7, 2013, Virginia Beach detectives interviewed Jordan Diangelo Champion at police headquarters after going to his home; the recorded interview lasted about six hours in two phases.
First phase (~1 hour): unadvised, rapport-building, appellant said he was in Chesapeake (Ipswich) when the victim Kristopher Lee was shot. Detectives left and returned.
Second phase (~5 hours): detectives informed appellant he was not free to leave and gave Miranda warnings; appellant affirmed understanding and then confessed to shooting Lee after being confronted with phone records and physical evidence. Interview ended with appellant calling his father and admitting guilt.
Appellant moved to suppress all statements, arguing: (1) he did not knowingly, intelligently, and voluntarily waive Miranda rights; and (2) police used an improper two-step interrogation to undermine midstream Miranda warnings. The trial court denied suppression; appellant pleaded conditional guilty and reserved the Miranda ruling for appeal.
On appeal, the Court of Appeals of Virginia reviewed the record de novo as to legal issues but deferred to the trial court’s factual findings; it affirmed the denial of suppression and appellant’s convictions.

Issue	Champion's Argument	Commonwealth's Argument	Held
Whether appellant knowingly, intelligently, and voluntarily waived Miranda rights	Waiver invalid due to being brought to HQ in unmarked car, lengthy pre-warning interrogation, low education/special-education background, warnings minimized by saying "real quick," and alleged threats about searching/waking his family	Waiver was valid: appellant was not in custody until warnings were given; warnings were read clearly; appellant understood and responded affirmatively; statements about searches were lawful investigative statements, not coercive threats	Court affirmed: totality of circumstances shows a knowing, intelligent, voluntary waiver and statements admissible
Whether detectives used an impermissible two-step interrogation to circumvent Miranda	The pre-warning custodial questioning and then midstream warnings rendered the subsequent waiver ineffective	Miranda protection applies only when custody exists; trial court found appellant was not in custody during the first phase, so no violation	Court declined to reach merits of two-step claim because appellant did not contest the trial court’s finding he was not in custody before warnings; claim fails

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes custodial warning and exclusionary rule for unwarned custodial interrogation)
Bradshaw v. Commonwealth, 228 Va. 484 (Va. 1985) (waiver of Miranda must be voluntary, knowing, and intelligent)
Rodriguez v. Commonwealth, 40 Va. App. 144 (Va. Ct. App. 2003) (totality of circumstances and suspect characteristics govern waiver inquiry)
Webber v. Commonwealth, 26 Va. App. 549 (Va. Ct. App. 1998) (Miranda applies only to custodial interrogation)
Jackson v. Commonwealth, 266 Va. 423 (Va. 2003) (Miranda waiver need not be in writing)