People v. Parker, 205 N.Y.S.3d 194

Mark Parker was convicted by jury in Queens County Supreme Court of criminal possession of a weapon in the second degree after a shooting incident in a public housing development.
After being shot and hospitalized, Parker made statements to police admitting he had fired a weapon, while still recovering from surgery, under medication, and physically restrained.
Parker moved to suppress these statements, arguing they were involuntarily made due to his medical condition and denial of medical assistance during interrogation.
The suppression hearing included evidence showing Parker was in pain, sedated, and physically incapacitated during questioning. The court denied suppression, finding a valid Miranda waiver.
At trial, Parker challenged the voluntariness of his statements and raised a Batson challenge regarding the prosecution’s jury strikes of African American male jurors.
On appeal, the Appellate Division reversed the conviction, finding errors in the trial court's handling of the suppression motion, jury instructions on voluntariness, and the Batson challenge.

Issue	People’s Argument	Parker’s Argument	Held
Whether Parker’s statements to police were	Miranda waiver was valid and statements were voluntary	Statements were involuntary due to medical condition and coercion	Statements were involuntary; suppression motion granted
voluntary and admissible
Whether the jury was properly instructed on	Instructions were sufficient	Jurors should have been told to disregard involuntary statements	Instructions were incomplete; new trial required
disregarding involuntary statements
Whether jury selection violated Batson	Strikes based on employment/life experience—not race	Strikes targeted African American male jurors; not equally applied	Strikes were pretextual; new trial warranted
(discriminatory peremptory strikes)

Miranda v. Arizona, 384 US 436 (U.S. 1966) (establishes requirements for custodial interrogation and Miranda waivers)
Mincey v. Arizona, 437 US 385 (U.S. 1978) (statement involuntary where defendant was critically ill and incapacitated)
Batson v. Kentucky, 476 US 79 (U.S. 1986) (prohibits race-based peremptory jury strikes)
People v. Thomas, 22 NY3d 629 (N.Y. 2014) (People must prove defendant’s statements were voluntary beyond a reasonable doubt)
People v. Guilford, 21 NY3d 205 (N.Y. 2013) (clarifies burden on People to show voluntary statements)
People v. Hecker, 15 NY3d 625 (N.Y. 2010) (explains Batson 3-step process for jury selection challenges)
People v. Graham, 55 NY2d 144 (N.Y. 1982) (jury must be instructed to disregard involuntary statements)