People of Michigan v. Crystal Fayla Hensley
331089
| Mich. Ct. App. | Mar 16, 2017Background
- Police executed a valid search warrant on the home of defendant Crystal Hensley’s husband; multiple armed officers (some masked) swept the house, found marijuana plants in locked rooms, and detained occupants in the living room.
- Defendant arrived ~45 minutes after the search began; Sergeant White (unmasked) told her the police had a warrant and that she was not under arrest, but did not tell her she was free to leave or give Miranda warnings.
- Sergeant White asked about medical-marijuana paperwork; defendant produced a patient card and either produced or identified paperwork in the bedroom, then called her husband to obtain a key/combination to the grow room and gave that information to police.
- Sergeant White later asked defendant to write a statement summarizing what she had told him; she wrote a short statement admitting she sometimes trimmed plants. She acknowledged the written words were hers and true.
- Defendant moved to suppress her statements, arguing custodial interrogation without Miranda warnings and involuntariness; after a two-day Walker hearing the trial court denied suppression. The Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Hensley) | Held |
|---|---|---|---|
| Whether defendant was in custody such that Miranda warnings were required | Interaction was noncustodial: defendant voluntarily returned home, was told she was not under arrest, was not handcuffed, questioning was brief and occurred in her home during a valid search | Defendant was effectively in custody: detained 1.5–2 hours, surrounded by armed/masked officers, never told she was free to leave, paraded past handcuffed family, twice isolated and questioned in bedroom | Court held noncustodial: reasonable person would not have felt free to leave given totality of circumstances; detention incidental to valid warrant search and questioning was limited and on-scene fact-finding |
| Whether statements were voluntary | Statements were voluntary: brief, nonrepetitive questioning; statement repeated prior verbal admissions; defendant understood and acknowledged the statement was true | Statements were involuntary: defendant felt she had no choice, was threatened with arrest, had limited education and writing ability, was scared and coerced | Court held voluntary: totality shows will not overborne; factors (age, education, short questioning, lack of physical abuse, ability to contact husband) favored voluntariness |
| Whether police exploited detention to create coercive environment | Police acted within authority to detain occupants during a search and asked limited, on-scene investigative questions | Defendant contends detention and officers’ conduct created coercion to obtain statements | Court held detention was lawful under Summers and related precedent; police did not create custodial coercion to trigger Miranda |
| Whether trial court sufficiently applied law and made findings | N/A (People defending ruling) | Trial court failed to expressly apply Miranda and omitted key factual findings on record | Court found trial court adequately considered Miranda and custody analysis; factual findings supported the ruling and remand unnecessary |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required during custodial interrogation)
- Michigan v. Summers, 452 U.S. 692 (1981) (occupants may be detained during execution of a search warrant)
- Oregon v. Mathiason, 429 U.S. 492 (1977) (noncustodial interview where subject informed he was not under arrest)
- Rhode Island v. Innis, 446 U.S. 291 (1980) (definition of interrogation and Miranda scope)
- California v. Beheler, 463 U.S. 1121 (1983) (custody inquiry focuses on formal arrest or restraint of freedom of movement)
- Stansbury v. California, 511 U.S. 318 (1994) (custody determination is objective)
- People v. Cipriano, 431 Mich. 315 (1988) (factors for voluntariness inquiry)