Robinson v. State
19 A.3d 952
Md.2011Background
- Robinson convicted of first degree murder and related offenses in Baltimore City Circuit Court based on three statements to police.
- Initial suppression motion denied; Court of Special Appeals affirmed in an unpublished opinion.
- Petition for writ of certiorari presented two questions concerning Miranda custody and jury note responses.
- First statement given at scene; bags placed on hands and transported to patrol car before further questioning.
- Second statement taken hours later at homicide unit; held for five hours in a holding cell before interview; Miranda rights not advised.
- Third statement taken about five weeks later after arrest, with Miranda rights advised and waived; detectives allegedly summarized prior statements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Robinson was in Miranda custody during the initial scene statement | Robinson was not in custody; free to leave, with only minimal restraint | Totality of circumstances suggested custodial interrogation | First statement not custodial; Miranda warnings not required |
| Whether the second, post-holding-cell statement violated Miranda and was admissible | Second statement was custodial and violated Miranda | Warnings could cure under Elstad; post-warning statement admissible | Second statement custodial and inadmissible in State's case-in-chief |
| Whether Seibert/Elstad framework applies to cure or bars admission of post-arrest statement | Warnings could cure under Elstad; Seibert not controlling here | Question-first strategy renders post-warning statements inadmissible under Seibert | Post-arrest statement improperly obtained; not admissible despite later warnings |
| Appropriate remedy on appeal | New trial with only first statement admissible | Maintain conviction if admissibility cured or on harmless-error review | Judgment reversed; remand for new trial restricting State to first statement only |
Key Cases Cited
- Oregon v. Mathiason, 429 U.S. 492 (1977) (not determinative; whether free to leave informs custody)
- Oregon v. Elstad, 470 U.S. 298 (1985) (warnings cure unwarned statement absent coercion)
- Missouri v. Seibert, 542 U.S. 600 (2004) (two-step interrogation violated Miranda when used to obtain initial unwarned confession)
- Cooper v. State, 163 Md.App. 70 (2005) (applied Seibert/Elstad analysis in Maryland context)
- Abeokuto v. State, 391 Md. 289 (2006) (totality of circumstances governs custody determination)