Louis Moreira v. State of Indiana, 10A01-1208-CR-351

Moreira was arrested Sept. 2, 2011 by Clark County Officers in connection with burglaries at Lyons and Dean residences; he possessed victim property.
Detective Proctor interrogated Moreira twice, first with an Advice of Rights—Interrogation form and Miranda warnings, followed by a signed waiver after Moreira studied the form.
First interrogation lasted 15 minutes; Moreira made incriminating statements about Lyons’ burglary.
About three hours later, a second interrogation occurred for 31 minutes, yielding statements about Lyons’ and Dean’s burglaries.
The State charged two Class B felony burglaries; the trial court admitted both interrogations over Moreira’s objection; Moreira was convicted.
On appeal, Moreira challenges the admissibility of the statements as involuntary waivers; the court affirms, holding the waivers were voluntary under the totality of circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of custodial statements was error due to Miranda waiver voluntariness.	State argues waiver voluntary and intelligent.	Moreira argues waiver involuntary due to misleading, hurried signing.	No abuse; waivers voluntary; convictions affirmed.

Ringo v. State, 736 N.E.2d 1209 (Ind. 2000) (standards for voluntariness and waiver)
Pruitt v. State, 834 N.E.2d 90 (Ind. 2005) (totality-of-circumstances voluntariness consideration)
Allen v. State, 686 N.E.2d 760 (Ind. 1997) (extensive criminal record considerations in voluntariness analysis)
Dickerson v. State, 257 Ind. 562, 276 N.E.2d 845 (Ind. 1972) (Dickerson distinction; oral explanation needed for waiver validity)
Luna v. State, 788 N.E.2d 832 (Ind. 2003) (recognition of Oregon v. Mathiason issues in waiver analysis)