State of Indiana v. DeAngelo Banks
2014 Ind. App. LEXIS 13
| Ind. Ct. App. | 2014Background
- Defendant DeAngelo Banks, diagnosed with schizoaffective disorder and housed in the psychiatric ward of New Castle Correctional Facility, was interviewed by Detective Michael Mitchell on December 7, 2010 while restrained and medicated.
- Mitchell did not know Banks was in the psychiatric ward or that he was medicated; he did not consult medical staff before the interview and did not read the Miranda form verbatim or obtain a signed waiver.
- During the interview Banks made detailed incriminating statements admitting to murders and post-mortem sexual conduct.
- Treating psychologist Dr. Maguire testified Banks had significant processing and comprehension difficulties at the time and advised waiting until his medication stabilized; she reported poor insight, judgment, and reasoning.
- The trial court held a suppression hearing, found the Miranda advisement unclear as to the right to counsel and that Banks’s waiver was not knowing given his mental condition, granted the motion to suppress, and the State appealed; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Banks) | Held |
|---|---|---|---|
| Whether Miranda warnings were adequately conveyed | Mitchell sufficiently informed Banks of all required warnings despite not reading form verbatim | Advisement was confusing, especially about right to appointed counsel before or during questioning | Miranda advisement was inadequate as it did not clearly convey right to counsel during questioning |
| Whether Banks validly waived Miranda rights and confession admissible | Banks understood and voluntarily waived rights; his answers and demeanor showed comprehension | Banks’s severe mental illness, medication status, restraints, and confusing advisement prevented a knowing, voluntary waiver | Waiver not knowing/voluntary under totality; confession suppressed |
| Whether coercive police conduct is required under Indiana Constitution to find involuntariness | State: coercive police activity is necessary to render a confession involuntary under both U.S. and Indiana Constitutions | Banks: Indiana Constitution may require voluntariness without proof of police coercion when defendant’s mental condition undermines free will | Court rejected claim that Ajabu requires coercion as absolute prerequisite; evaluated voluntariness under Indiana standards and suppressed statement |
| Standard/burden for voluntariness under Indiana law | State: must prove voluntariness beyond reasonable doubt; factual showing met here | Banks: State failed to meet burden given Dr. Maguire’s testimony and his confusion | Court applied Indiana voluntariness test, found substantial evidence supporting trial court that State did not meet its burden and affirmed suppression |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (requirement to warn suspects of rights and right to counsel)
- Florida v. Powell, 559 U.S. 50 (warnings judged by whether they reasonably convey Miranda rights)
- Colorado v. Connelly, 479 U.S. 157 (federal voluntariness inquiry; coercive police conduct central to Fifth Amendment analysis)
- Linthicum v. State, 511 N.E.2d 1026 (discussing intoxication, coercion, and voluntariness under Indiana law)
- Ajabu v. State, 693 N.E.2d 921 (Indiana precedent on voluntariness and role of compulsion in confessions)
- Pruitt v. State, 834 N.E.2d 90 (Indiana burden: state must prove waiver and voluntariness beyond a reasonable doubt under Article 1, § 14)