State v. Carroll
103 So. 3d 929
Fla. Dist. Ct. App.2012Background
- State appeals order suppressing Carroll's custodial statements to police.
- Detective Duff questioned Carroll at the sheriff's office about alleged lewd conduct with a minor, Carroll confessed.
- Carroll moved to suppress, alleging the detective's misleading statements induced self-incrimination.
- Trial court suppressed, finding the confession involuntary due to inducement, minimization of seriousness, possible victim consent, Carroll's limited education, and lack of prior experience with police.
- Appellate court reverses, holding the interrogation did not render the confession involuntary; totality of circumstances did not coercively compel confession.
- Interrogation lasted about 22 minutes; Carroll had a ninth-grade education; recording shows intelligent conversational ability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the detective's statements create a promise of leniency? | State argued no express promise of leniency, | Carroll argued statements created inducement, | No; not a promise of leniency |
| Was the totality of circumstances coercive to render the confession involuntary? | State contends factors did not coerce confession | Carroll contends education, interrogation length, and misstatements coerced | Not coercive; confession voluntary |
| Did mischaracterizing victim consent render the confession involuntary? | State asserts misstatement did not coercively force confession | Carroll asserts misrepresentation affected voluntariness | Misrepresentation alone insufficient for involuntariness |
Key Cases Cited
- Blake v. State, 972 So.2d 839 (Fla. 2007) (promises may be coercive if quid pro quo)
- Bush v. State, 461 So.2d 936 (Fla. 1984) (promises of cooperation; not per se coercive)
- State v. Walter, 970 So.2d 848 (Fla. 2d DCA 2007) (express promise of leniency may render confession involuntary)
- Day v. State, 29 So.3d 1178 (Fla. 4th DCA 2010) (multiple promises of help distinguished)
- Ramirez v. State, 15 So.3d 852 (Fla. 1st DCA 2009) (distinguishable from cases with multiple promises)
- Wyche v. State, 906 So.2d 1142 (Fla. 1st DCA 2005) (deception as investigative tool; absence of coercion)
- Peterson v. State, 810 So.2d 1095 (Fla. 5th DCA 2002) (education/experience factors considered; not alone coercive)
- Lages v. State, 640 So.2d 151 (Fla. 2d DCA 1994) (totality of circumstances factors for voluntariness)
- Martin v. State, — So.3d — (Fla. 2012) (voluntariness test based on totality of circumstances)
- Brockelbank v. State, 407 So.2d 368 (Fla. 2d DCA 1981) (premonition of immediate release not always coercive)