State v. DeAnthony Allen, 68 A.3d 512

Defendant DeAnthony Allen was charged with first-degree child abuse (Brendan’s Law, § 11-9-5.3(b)(1)) for injuries suffered by his four-month-old son in November 2010; jury convicted and sentencing was 20 years to serve.
At the police station, the 18-year-old defendant read, initialed, and signed a Miranda rights form and, about 15 minutes later, wrote and signed a statement admitting to shaking and squeezing the infant.
Defendant moved pretrial to suppress his statement (alleging an involuntary Miranda waiver) and to dismiss the information as unconstitutionally vague; both motions were denied.
Trial evidence included the mother’s timeline of events and expert medical testimony diagnosing abusive head trauma, subdural hemorrhage, retinal hemorrhages, and multiple rib fractures.
After conviction, defendant moved for judgment of acquittal and for a new trial (arguing insufficiency of evidence without the confession); both were denied. Defendant appealed.

Issue	State's Argument	Allen's Argument	Held
Whether § 11-9-5.3 is unconstitutionally vague as applied	Statute clearly defines "serious bodily injury," providing fair notice; evidence fits statutory definition	Statute is vague, indistinguishable between first- and second-degree abuse	Statute not vague as applied; motion to dismiss denied; conviction affirmed
Whether defendant knowingly and voluntarily waived Miranda rights	Defendant read rights aloud, initialed each right, checked understanding, and signed the form; testimony was credible	Age, education (HS dropout), and brief time with form (<5 minutes) rendered waiver involuntary or unknowing	Waiver was knowing and voluntary; motion to suppress properly denied
Whether there was insufficient evidence without the confession (motion for acquittal/new trial)	Medical and eyewitness evidence, plus confession, supported conviction; confession admissible	Without the confession evidence would be insufficient	Because confession was admissible, motions for acquittal and new trial fail; conviction affirmed

Miranda v. Arizona, 384 U.S. 436 (landmark rule requiring warnings before custodial interrogation)
Village of Hoffman Estates v. The Flipside, Hoffman Estates, Inc., 455 U.S. 489 (vagueness challenges examined in light of facts and notice concerns)
United States v. Mazurie, 419 U.S. 544 (statutory vagueness must be tested in light of facts of case)
State v. Sahady, 694 A.2d 707 (Rhode Island: vagueness inquiry focuses on whether defendant had sufficient notice)
State v. Fonseca, 670 A.2d 1237 (vagueness challenge examined in context of case facts)
State v. Stierhoff, 879 A.2d 425 (Fourteenth Amendment vagueness standard explained)
State v. Jimenez, 33 A.3d 724 (state must prove waiver of Miranda by clear and convincing evidence)
State v. Kryla, 742 A.2d 1178 (teenage suspect who initialed and signed rights form found to have knowingly waived rights)