People v. Mandoline
2017 IL App (2d) 150511
| Ill. App. Ct. | 2017Background
- On July 22, 2012 a fire started in Paula Morgan’s car at her home; Morgan died from inhalation and a house fire severely burned Jason Cassiday. Arson evidence (paper in gas fill tube) suggested intentional ignition.
- Defendant Todd Mandoline had attended Morgan’s party the prior night, engaged in a heated argument with her, threatened “I hope you all die,” and was driven away; partygoers later saw a shadowy figure near the house and one received a call from defendant saying he was returning.
- Police interviewed partygoers, then went to defendant’s home. Defendant voluntarily accompanied officers to the station, was patted down, Mirandized, and questioned; he first asked for counsel at 8:18 a.m., questioning continued until about 10:26 a.m., then resumed after defendant reinitiated discussion and executed a written waiver at ~11:36 a.m., after which he confessed to placing a lit paper in the gas tank.
- Trial court suppressed statements between 8:18–10:26 a.m., denied motion to quash arrest and admitted post‑11:36 a.m. statements; it suppressed an unduly suggestive photo identification but allowed descriptive testimony; jury convicted defendant of first‑degree murder and aggravated arson.
- On appeal defendant challenged (1) timing/probable cause for arrest, (2) whether he reinitiated questioning after invoking counsel, (3) voluntariness/knowing waiver, (4) violation of recording statute (725 ILCS 5/103‑2.1), and (5) refusal of a foreseeability jury instruction; the appellate court affirmed.
Issues
| Issue | People’s Argument | Mandoline’s Argument | Held |
|---|---|---|---|
| Probable cause / timing of arrest | Probable cause existed by ~7:45 a.m.; arrest at station was lawful | Arrest occurred earlier (at home or on arrival) and lacked probable cause | Defendant was arrested by ~7:45 a.m., but probable cause existed at that time — denial of motion to quash affirmed |
| Reinitiation after invocation of counsel | Defendant reinitiated at second smoking break and signed waiver; subsequent statements admissible | Police badgered/engineered reinitiation after ignoring earlier invocation; reinitiation involuntary | Trial court’s factual finding that defendant reinitiated was not against manifest weight; confession admitted |
| Voluntariness / valid waiver | Post‑waiver statements were voluntary, knowing, intelligent (Miranda given twice; short detention; no physical abuse) | Earlier police misconduct overbore his will; waiver was not knowing/voluntary | Totality of circumstances supports voluntariness; waiver valid; admission affirmed |
| Compliance with 725 ILCS 5/103‑2.1 (recording) | Recording not feasible for outdoor smoking breaks (no audio); State proved voluntariness/reliability | Smoking breaks were custodial interrogations that should have been recorded; statements presumptively inadmissible | Issue forfeited; in any event court found no reversible error — State met preponderance and/or recording not feasible |
| Jury instruction (foreseeability / proximate cause) | Felony‑murder instructions given (defendant caused death by committing arson) sufficient | Needed IPI 7.15A (foreseeability) because death spread to house via unforeseeable factors | Refusal of IPI 7.15A proper: foreseeability instruction is for third‑party caused deaths; here defendant’s act caused death, so instructions given were adequate |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation rights require warnings and counsel protections)
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (after requesting counsel, police may not resume interrogation unless defendant initiates)
- People v. Wear, 229 Ill. 2d 545 (Ill. 2008) (probable cause standard and totality of circumstances)
- People v. House, 141 Ill. 2d 323 (Ill. 1990) (court’s voluntariness inquiry and lengthy interrogation precedents)
- People v. Lowery, 178 Ill. 2d 462 (Ill. 1997) (proximate‑cause theory in felony‑murder when death results from third party)
- People v. Causey, 341 Ill. App. 3d 759 (Ill. App. Ct. 2003) (felony‑murder strict‑liability discussion; foreseeability unnecessary when defendant caused death)
- Dorsey v. United States, 60 A.3d 1171 (D.C. 2013) (extreme badgering can negate reinitiation and voluntariness)