People of Michigan v. Dionte Darryl Travis
331479
| Mich. Ct. App. | Jun 20, 2017Background
- In Sept. 2015 defendant (17 at offense) was convicted of armed robbery; a mistrial occurred on an associated first-degree felony-murder count. He was retried Dec. 2015 and convicted of felony murder. Sentences: 16–40 years (robbery) and 30–60 years (felony murder).
- Victim Bilal Berreni was killed July 29, 2013; body identified March 2014. Defendant arrested Aug. 2014, initially gave false name and birthdate, then made inculpatory statements after police questioning.
- Defendant was advised of Miranda rights by Investigator Ira Todd, initial interview lasted ~1 hour; defendant initialed and signed a rights form and initially denied involvement.
- Approximately three hours later Detective Shea and Trooper Drew interviewed defendant, provided a meal, did not reread Miranda form but confirmed defendant remembered being advised; defendant then admitted involvement and signed a written statement.
- Defendant moved to suppress custodial statements, arguing his waiver was involuntary because he did not understand his rights; trial court denied suppression, finding the waiver and statements voluntary, and the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendant’s custodial statements were made only after an involuntary, unknowing waiver of Miranda rights | Statements admissible; defendant knowingly and voluntarily waived rights; interrogation circumstances do not show coercion | Waiver was not knowing/understanding; defendant confused and coerced, so statements involuntary | Court affirmed suppression denial: totality of circumstances shows waiver and statements were voluntary, knowing, and intelligent |
| Whether failure to reread Miranda warnings before the second interrogation rendered statements inadmissible | Re-reading not required; prior advisal and confirmation sufficed; voluntariness governs admissibility | Failure to re-administer warnings invalidated subsequent statements because defendant didn’t understand rights | Held: rereading not required; factual voluntariness inquiry governs admissibility; confirmation that defendant understood was adequate |
| Whether trial court’s factual findings (credibility, voluntariness) were clearly erroneous | Trial court’s findings supported by record (initial false identity, prior experience with police, signed form, meal provided, lack of threats) | Defendant’s testimony of confusion, lack of phone call request, physical smallness indicate coercion/involuntariness | Held: appellate court defers to trial court credibility findings; no clear error in finding waiver voluntary |
Key Cases Cited
- People v Cipriano, 431 Mich. 315 (1988) (sets totality-of-circumstances test for voluntariness of statements)
- People v Akins, 259 Mich. App. 545 (2003) (custodial statements admissible only after voluntary, knowing, intelligent waiver)
- People v Godboldo, 158 Mich. App. 603 (1987) (failure to reread Miranda warnings does not automatically render later statements inadmissible; voluntariness is the factual inquiry)
- People v Cortez (On Remand), 299 Mich. App. 679 (2013) (constitutional protection against compelled self-incrimination reiterated)
- People v Roberts, 292 Mich. App. 492 (2011) (standard of review for suppression rulings: de novo for legal conclusions; factual findings for clear error)