Miles v. State
60 So. 3d 447
Fla. Dist. Ct. App.2011Background
- Miles was convicted of sexual battery with a deadly weapon and kidnapping with a deadly weapon, each requiring a life sentence served consecutively.
- DNA testing of a 1990 victim kit, conducted in 2003 and entered into a database in 2008, linked Miles to the crimes.
- In 2008, detectives interviewed Miles in prison following the DNA hit, informing him they had his DNA.
- During the interview Miles initially resisted discussing the case and made statements minimizing involvement.
- The trial court denied Miles’ motion to suppress statements after invoking his right to silence; the DNA testing was challenged via a motion in limine and was not excluded.
- The appellate court reversed and remanded for a new trial due to the improper denial of suppression of statements obtained after Miles invoked his right to remain silent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Suppression of post-invocation statements | Miles argues the statements were compelled after invoking silence | State contends the invocation was equivocal or not clearly invoked | Remand for new trial; suppression error established |
| DNA evidence/related testimony in limine | Miles sought to exclude DNA evidence and testimony | State sought to admit DNA evidence and testimony linking Miles | No reversible error; denial of the motion in limine affirmed |
Key Cases Cited
- Cuervo v. State, 967 So.2d 155 (Fla.2007) (clear invocation of right to remain silent; authorities require termination of interrogation)
- Owen v. State, 696 So.2d 715 (Fla.1997) (equivocal requests to speak after waiver require clarification of intent)
- Almeida v. State, 737 So.2d 520 (Fla.1999) (equivocal inquiries; waiver timing matters)
- DiGuilio, 491 So.2d 1129 (Fla.1986) (harmless error standard for trial court missteps)
- State v. Hunt, 14 So.3d 1035 (Fla.2d DCA 2009) (post-invocation police conduct standards)
- Traylor v. State, 596 So.2d 957 (Fla.1992) ( Miranda requirements and invocation guidance)
- Michigan v. Mosley, 423 U.S. 96 (U.S. 1975) (necessity of scrupulous compliance after invocation)
- Dubon v. State, 982 So.2d 746 (Fla.1st DCA 2008) (reversal when statements obtained post-invocation)