Lanny Woosley v. Neil McDowell
699 F. App'x 709
| 9th Cir. | 2017Background
- Woosley was arrested and questioned at a police station; he initially denied carjacking but later confessed during the interview.
- He gave a self-recitation of Miranda rights rather than receiving a full officer-administered warning.
- At one point Woosley asked for an attorney but also continued asking questions and reengaging the officer.
- Woosley challenged admissibility of his statements on Miranda, right-to-counsel, and right-to-remain-silent grounds, plus a claim that police used a two-step Seibert interrogation to circumvent Miranda.
- The California Court of Appeal rejected Woosley’s claims; the district court denied habeas relief, and Woosley appealed under AEDPA standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Custody for Miranda purposes | Woosley: was in custody before confession, so warnings required | State: not in custody until he admitted carjacking | Court: Not unreasonable to find he was not in custody until confession |
| Invocation of right to counsel | Woosley: unambiguously asked for an attorney | State: request was ambiguous because he immediately asked questions | Court: request was ambiguous; no clear invocation |
| Invocation of right to remain silent | Woosley: repeatedly tried to remain silent | State: he repeatedly reinitiated conversation so did not unambiguously invoke | Court: fairminded jurists could disagree; state rejection presumed reasonable |
| Seibert two-step interrogation | Woosley: officers deliberately used question-first tactic to evade Miranda | State: no evidence of deliberate Seibert strategy; interrogation resembled Elstad | Court: reasonable to treat interview like Elstad, not Seibert |
| Adequacy of self-recitation of Miranda rights | Woosley: police must give full warnings; his recital insufficient | State: suspect’s recitation, endorsed by detective, conveyed Miranda warnings | Court: reasonable to find self-admonition sufficient under Powell |
Key Cases Cited
- Harrington v. Richter, 562 U.S. 86 (AEDPA standard and "fairminded jurists" test)
- Thompson v. Keohane, 516 U.S. 99 (custody inquiry for Miranda purposes)
- Davis v. United States, 512 U.S. 452 (requirement that request for counsel be unambiguous)
- Berghuis v. Thompkins, 560 U.S. 370 (must unambiguously invoke right to remain silent)
- Missouri v. Seibert, 542 U.S. 600 (two-step interrogation doctrine)
- Oregon v. Elstad, 470 U.S. 298 (subsequent voluntary confession after unwarned admission may be admissible)
- Florida v. Powell, 559 U.S. 50 (sufficiency of Miranda warnings)
- Amado v. Gonzalez, 758 F.3d 1119 (presumption that state supreme court rejected claim on merits)