Sonny Eric Pierce v. State of Florida
221 So. 3d 1218
Fla. Dist. Ct. App.2017Background
- Pierce was arrested for involvement in a shooting and interrogated while handcuffed; the interrogation was video recorded.
- Detective Wray read Miranda warnings and Pierce signed a written waiver after some colloquy.
- During questioning, the detective told Pierce that "it can’t hurt you to talk with me" and encouraged cooperation.
- Pierce then confessed to shooting at a car after a drug sale dispute; those statements were used extensively at trial.
- Pierce moved to suppress his custodial statements under Miranda and Florida law; the trial court denied suppression without making factual findings.
- The appellate court reviewed the recording and transcript and concluded the waiver was invalid due to the detective’s misstatement, reversed the conviction, vacated sentences, and remanded for a new trial; the court upheld a separate challenge to the cellphone-search warrant.
Issues
| Issue | Plaintiff's Argument (Pierce) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Validity of Miranda waiver | Waiver was involuntary/unknowing because officer misled him by saying talking wouldn’t hurt him, undermining understanding of rights | Warnings were read, written waiver signed; statement was a permissible persuasion and Pierce voluntarily chose to talk | Waiver invalid; misstatement vitiated voluntariness — suppression required; reversal and remand for new trial |
| Admissibility of custodial statements | Statements obtained in violation of Miranda and Traylor — must be suppressed | Statements admissible because waiver was knowing, voluntary, and not induced by coercion | Court agreed with Pierce; statements inadmissible for State’s case-in-chief |
| Sufficiency of affidavit for cellphone search warrant | (Raised by Pierce) affidavit failed to show probable cause | Affidavit adequately alleged probable cause for the search | Court rejected challenge — warrant affidavit adequate |
| Harmless error / sentencing issues | Use of suppressed statements and sentencing errors require reversal | Some sentencing/score sheet errors but not outcome-determinative | Reversal and vacatur of sentences due to suppression issue; other sentencing errors moot on remand |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishing warnings required for custodial interrogation)
- Dickerson v. United States, 530 U.S. 428 (reinforcing Miranda as constitutional rule)
- Moran v. Burbine, 475 U.S. 412 (standards for knowing and voluntary waiver)
- Brookins v. State, 704 So.2d 576 (Fla. 1st DCA 1997) (two-pronged waiver inquiry under Florida law)
- Ramirez v. State, 739 So.2d 568 (misleading/promises vitiate Miranda waiver)