Stanton v. Commonwealth
2011 Ky. LEXIS 138
Ky.2011Background
- Stanton’s stepson alleged sexual abuse; police interviewed child, then Stanton, after Miranda warnings were given.
- Two recorded/unrecorded interviews yielded admissions; one confession occurred at the station, another during a subsequent interview.
- Stanton had bipolar disorder and low IQ (approximately 73–82) per KCPC evaluation.
- A grand jury later indicted for rape and sodomy, with a later amended indictment adding 33 more counts; Stanton eventually pled guilty to one rape and one sodomy charge.
- Stanton moved to suppress the two December statements; suppression denied; he pled guilty conditioned on appellate review of the suppression ruling.
- Court held the statements were voluntary and not coerced under totality of circumstances; the plea preserved appellate review of suppression ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the statements were voluntary given the alleged coercive removal threat | Stanton argues removal threat coerced confession | Commonwealth contends no coercion under totality of circumstances | No coercion; statements voluntary |
| Whether informing about potential removal of children was improper coercion | Stanton claims threat to remove children overbore will | State law context allowed informing next steps in child-abuse cases | Not coercive; warning framed as a possible next step, not an unlawful threat |
| Role of Miranda warnings vs. totality of circumstances in voluntariness | Warnings alone aren’t determinative; coercion still possible | Warnings plus circumstances show voluntariness | Miranda warnings plus circumstances supported voluntariness; not overbroad coercion |
Key Cases Cited
- Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (voluntariness requires free choice, not coercive police activity)
- Connelly v. United States, 479 U.S. 157 (U.S. 1986) (coercive police activity may render confessions involuntary)
- Mills v. Commonwealth, 996 S.W.2d 473 (Ky. 1999) (totality of circumstances standard for voluntariness)
- Lynumn v. Illinois, 372 U.S. 528 (U.S. 1963) (threats to child custody can render confession involuntary)
- Tingle v. United States, 658 F.2d 1332 (9th Cir. 1981) (threats referencing penalties and child separation can coercively induce confession)
- Medina v. People, 25 P.3d 1216 (Colo. 2001) (coercive threats regarding child and family can invalidate confession)
- Henson v. Commonwealth, 20 S.W.3d 466 (Ky. 1999) (confession sustained despite concerns about coercion in sexual abuse case)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (Miranda warnings are not conclusive of voluntariness; totality matters)