State of Maine v. Michael R. McNaughton, 168 A.3d 807

Background

On April 9–10, 2013 Michael McNaughton, with accomplices, attacked and killed Romeo Parent; the body was later disposed in a stream. Morton later cooperated with police; True was convicted separately.
Police interviewed McNaughton twice at the Lewiston PD (evening April 11 and early morning April 12). Officers observed visible injuries, photographed them, and collected his clothing; McNaughton later admitted involvement during the second interview.
McNaughton moved to suppress (1) incriminating statements as involuntary and made after he invoked the right to remain silent, and (2) photographs of injuries taken without a warrant.
The suppression hearing court found both interviews custodial but concluded McNaughton knowingly waived Miranda rights, did not unambiguously invoke the right to cut off questioning until late in the second interview, and that most statements were voluntary; the court also found photographing visible injuries and seizing clothing justified by exigent circumstances and plain-view/probable-cause reasoning.
After a jury trial McNaughton was convicted of murder and hindering apprehension; he sought a new trial alleging the State presented perjured testimony; the trial court denied the motion and imposed life plus concurrent 10 years.
On appeal the Maine Supreme Judicial Court affirmed: it upheld the suppression rulings (Miranda invocation and voluntariness; Fourth Amendment exceptions for photos/clothing) and rejected the perjury-based new-trial claim.

Issues

Issue	Plaintiff's Argument (McNaughton)	Defendant's Argument (State)	Held
Whether McNaughton unambiguously reasserted his Miranda right to remain silent, requiring cessation of questioning	McNaughton contends he reasserted the right before incriminating statements and questioning should have stopped	State argued his statements were ambiguous and did not clearly invoke the right, so questioning could continue	Court held his comments were ambiguous; no clear, unambiguous invocation until late in second interview, so suppression denied for earlier statements
Whether McNaughton’s incriminating statements were voluntary	McNaughton argued officers’ interrogation tactics, suggestions about mitigating factors/leniency, and custodial pressure rendered confessions involuntary	State argued warnings, custodial advisals, and lack of concrete promises supported voluntariness under the totality of circumstances	Court held statements (up to the clear assertion) were voluntary; abstract references to mitigation did not amount to improper promises of leniency
Whether photographs of visible injuries taken without a warrant violated the Fourth Amendment	McNaughton argued photos (including some of injuries revealed when he removed clothing) required a warrant	State argued visible injuries were exposed to public view (no expectation of privacy) and photos of covered injuries were lawful because seizure of clothing was supported by probable cause and exigent circumstances; plain-view applied	Court held visible injuries could be photographed without a warrant; taking clothing and photographing previously covered injuries was justified by probable cause/exigent circumstances and plain-view seizure
Whether alleged perjured testimony by State’s witnesses warranted a new trial	McNaughton claimed the State knowingly or recklessly presented perjured testimony that deprived him of a fair trial	State argued inconsistencies were credibility matters for the jury, not evidence of perjury used knowingly by the State	Court held defendant failed to show actual perjury or knowing use of false testimony; inconsistencies were credibility issues and did not warrant a new trial

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes Miranda warnings and right to cut off questioning)
Berghuis v. Thompkins, 560 U.S. 370 (U.S. 2010) (invocation of right to remain silent must be unambiguous)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (ambiguity standard for invocation of right to counsel applicable to Miranda invocations)
Katz v. United States, 389 U.S. 347 (U.S. 1967) (Fourth Amendment protects reasonable expectations of privacy)
Horton v. California, 496 U.S. 128 (U.S. 1990) (plain-view doctrine and seizure admissibility)
State v. Marden, 673 A.2d 1304 (Me. 1996) (no duty to stop questioning when suspect’s invocation is ambiguous)
State v. Kittredge, 97 A.3d 106 (Me. 2014) (voluntariness standard for confessions)
State v. Hunt, 151 A.3d 911 (Me. 2016) (analysis of promises/leniency and voluntariness)
State v. King, 708 A.2d 1014 (Me. 1998) (clarifies requirement that invocation be sufficiently clear for a reasonable officer)