State v. Campbell, 1511002338A & B

Defendant Rondree Campbell was arrested and interviewed by Dover detectives on Nov. 4, 2015; interrogation was video-recorded in segments over many hours.
Detective Warren read Miranda rights; Campbell initially agreed to talk.
During a heated exchange, Campbell said “Bye.” When asked “You done talking?” he replied “Yeah,” and Detective Warren left the room.
Over the next nine hours officers intermittently re‑approached and resumed questioning (including Sergeant Knight in the cell block and unrecorded car discussions), after which Campbell admitted to the shooting and led officers to firearms.
Late that night Campbell was re‑Mirandized; he gave minimal responses (nods/short answers). Campbell moved to suppress all statements as violating his Miranda right to remain silent and as involuntary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Campbell invoked his Miranda right to remain silent when he said “Bye” and answered “Yeah” to “You done talking?”	State: “Bye” was ambiguous and not an unambiguous invocation.	Campbell: His words and follow‑up were an unambiguous invocation to stop questioning.	Held: Unambiguous invocation. The follow‑up question by the detective clarified any ambiguity, and Campbell’s “Yeah” showed he was done talking.
Whether statements made after the invocation (including later re‑Mirandization) are admissible	State: Subsequent questioning and later Miranda warnings cured any earlier defect; interactions were not coercive.	Campbell: Officers failed to scrupulously honor his invocation; later warnings did not purge the taint.	Held: Suppressed. Officers did not scrupulously honor the invocation; interruptions were brief, re‑questioning concerned the same crime, and later Miranda warnings were ineffective to cure the prior violation.

Miranda v. Arizona, 384 U.S. 436 (1966) (requires advising of rights and cessation of interrogation on invocation)
Michigan v. Mosley, 423 U.S. 96 (1975) (police may reinitiate after significant break, fresh warnings, and questioning limited to a different crime)
Edwards v. Arizona, 451 U.S. 477 (1981) (limits on reinitiation after request for counsel)
Dodson v. State, 513 A.2d 761 (Del. 1986) (45‑minute resumption about same subject without fresh warnings violated right)
Draper v. State, 49 A.3d 807 (Del. 2002) (police must clarify ambiguous invocation)
Hubbard v. State, 16 A.3d 912 (Del. 2011) (state bears burden to prove waiver of Miranda rights)
DeShields v. State, 534 A.2d 630 (Del. 1987) (defendant may reinitiate interrogation only if voluntary and informed)
Commonwealth v. Smith, 46 N.E.3d 984 (Mass. 2016) (statements like “I’m done” are unambiguous invocations)
People v. Arroya, 988 P.2d 1124 (Colo. 1999) (same)