State of Iowa v. Adam Golden McCain, 19-1810

Background

On Feb. 5, 2019 a woman was found stabbed and later died; a passerby identified Adam McCain as the assailant.
A deputy stopped McCain at a damaged/disabled white car; during roadside custodial questioning McCain said, “I plead the fifth.” The deputy asked a few more brief questions and McCain was taken to jail.
DCI and Keokuk officers obtained a search warrant for McCain’s person/clothing; they awakened McCain ~7 hours after custody to execute the warrant.
McCain initiated conversation while the search was being executed; officers told him they would talk after finishing the warrant. After the search, McCain agreed to talk, received full Miranda warnings, nodded to waive, and confessed at the jail; an audio recording exists.
While in jail McCain made phone calls to relatives in which he made additional incriminating admissions.
McCain was convicted of first-degree murder after a bench trial and appealed, arguing Miranda violations, involuntariness of waiver, a rule requiring objective proof of post-invocation waivers, Iowa-constitutional protections, and suppression of the phone calls as fruit of the poisonous tree.

Issues

Issue	State's Argument	McCain's Argument	Held
Did officers violate McCain’s Fifth Amendment right by reinitiating questioning after he invoked silence?	Second interview was permissible: officers briefly continued roadside questioning but then ceased; ~7‑hour gap; fresh Miranda warnings; different officers; McCain initiated and agreed to talk.	“I plead the fifth” was an unequivocal invocation that had to be scrupulously honored; post‑invocation questioning and waiver were invalid.	Court: Invocation was unequivocal but, viewing Mosley factors and totality, rights were scrupulously honored and the jail interview lawful. Admission affirmed.
Was McCain’s Miranda waiver at the jail voluntary and knowing without written/video proof?	Waiver was voluntary: McCain initiated contact, was repeatedly told he need not answer, chose the room, received full Miranda warnings, nodded to waive, and spoke without coercion.	Lack of written or video proof and lack of audible verbal waiver show waiver was not voluntary or knowing.	Court: Waiver was knowing/voluntary under the totality of circumstances; head nod credible; absence of video/written proof did not require suppression.
Should courts impose a per se requirement that post‑invocation waivers be objectively proved by writing/video?	Existing Iowa precedent declines a per se recording/ written waiver rule; no basis to impose a new requirement.	Court should require objective written or video evidence of post‑invocation waivers or at least heavily weigh absence of such proof.	Court: Declined to adopt any per se recording/written requirement; failure to record may be weighed but did not defeat waiver here.
Are McCain’s jail phone calls to relatives inadmissible as fruit of the poisonous tree?	Calls admissible: (1) McCain did not preserve a fruit‑of‑the‑tree claim at trial and relied on a different statutory ground below; (2) even on the merits the police interview was lawful so there is no poisonous tree.	Calls flowed from the illegal interrogation/confession and must be suppressed.	Court: Rejected on preservation grounds and on the merits—since the confession was lawfully obtained, the calls were not fruit of a poisonous tree.

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings and waiver standards)
Michigan v. Mosley, 423 U.S. 96 (1975) (requires that an invocation of silence be "scrupulously honored" before resuming interrogation)
Moran v. Burbine, 475 U.S. 412 (1986) (waiver must be knowing, intelligent, and voluntary; totality test)
Wong Sun v. United States, 371 U.S. 471 (1963) (fruit‑of‑the‑poisonous‑tree principle)
State v. Palmer, 791 N.W.2d 840 (Iowa 2010) (applies Mosley factors and totality review under Iowa law)
State v. Madsen, 813 N.W.2d 714 (Iowa 2012) (declines to impose a per se recording requirement for interrogations)
State v. Hajtic, 724 N.W.2d 449 (Iowa 2006) (encourages but does not require videotaping custodial interrogations)