Matthew C. Stechauner v. Judy P. Smith
2017 U.S. App. LEXIS 5582
| 7th Cir. | 2017Background
- On Nov. 22, 2004 Stechauner was treated for an accidental self-inflicted shotgun wound at a hospital; a nurse discovered a bag of bullets and called police. Officers (one in uniform) questioned him in a hospital room for ~90 minutes without Miranda warnings; he later revealed the bullets and gun location.
- After discharge he was handcuffed in a cruiser, directed officers to the gun (or his friend did), and assisted (shouted) how to remove a casing; Miranda warnings were not given until hours later at the station, after which he confessed to multiple crimes.
- Trial court credited police testimony that Stechauner was not in custody at the hospital and denied suppression of hospital statements, cruiser statements, and the shotgun; admitted all evidence. Stechauner pleaded no contest to second-degree reckless homicide and armed robbery and was sentenced.
- Stechauner pursued state post-conviction relief and appeals. The Wisconsin courts rejected Miranda and voluntariness claims (2007 decision) and later rejected ineffective-assistance claims that alleged trial counsel should have called witnesses and introduced hospital records (2010 decision). Wisconsin Supreme Court denied review.
- Stechauner filed a §2254 habeas petition; district court denied relief and an evidentiary hearing (cert. of appealability granted on Miranda and Strickland claims). Seventh Circuit affirms, applying AEDPA deference and concluding state courts reasonably applied Miranda, voluntariness, and Strickland standards; Pinholster bars a federal evidentiary hearing.
Issues
| Issue | Plaintiff's Argument (Stechauner) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether hospital statements required Miranda warnings (was Stechauner "in custody"?) | Hospital questioning was custodial (handcuffed, in gown, IV, officers present) so warnings required | Officers’ testimony showed no custody: no restraints, free to leave, questioned as patient; objective circumstances not custodial | Court held hospital interview was noncustodial — no Miranda violation; state finding reasonable under AEDPA |
| Whether cruiser statements (location of gun, advice about pliers) should be suppressed as custodial interrogation | Statements made while in handcuffs/cruiser required Miranda and were product of interrogation | Statements were volunteered/not the product of police interrogation (friend’s comment; instruction to use pliers was unsolicited) | Court held statements were volunteered or not police interrogation — admissible |
| Whether statements were involuntary (due to pain meds or promises of help) | Medications and officer’s promise to "help" rendered statements involuntary/coerced | No coercive police activity: meds were hospital-administered; officer’s "help" statement was investigatory, not a leniency promise | Court held no coercion; voluntariness upheld |
| Whether trial/post-conviction counsel were ineffective for failing to call witnesses or introduce hospital record (prejudice under Strickland) | Missing witnesses and hospital record would have shown custody/intoxication and changed suppression outcome | Proposed witnesses had no material knowledge of hospital interrogation; hospital record did not show custody during questioning; no reasonable probability of different outcome | Court held state court reasonably concluded no prejudice under Strickland; ineffective-assistance claim fails |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (prophylactic Miranda warnings required for custodial interrogation)
- Rhode Island v. Innis, 446 U.S. 291 (interrogation includes police words or actions reasonably likely to elicit incriminating response)
- Berkemer v. McCarty, 468 U.S. 420 (custody test: freedom of action curtailed to degree associated with formal arrest)
- Howes v. Fields, 565 U.S. 499 (custody assessed by objective totality-of-circumstances; whether reasonable person would feel free to leave)
- Stansbury v. California, 511 U.S. 318 (officers’ subjective beliefs irrelevant to custody inquiry)
- Colorado v. Connelly, 479 U.S. 157 (coercive police activity is necessary predicate for involuntariness finding)
- Schneckloth v. Bustamonte, 412 U.S. 218 (voluntariness judged by totality of circumstances)
- Strickland v. Washington, 466 U.S. 668 (two-prong ineffective assistance standard: deficient performance and prejudice)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference: state-court decision must be unreasonable to justify habeas relief)
- Cullen v. Pinholster, 563 U.S. 170 (§2254(d)(1) review limited to state-court record; limits federal evidentiary hearings)
- Buck v. Davis, 137 S. Ct. 759 (rearticulation and application of Strickland standard on prejudice)