State v. Diaz
2014 SD 27
| S.D. | 2014Background
- Jasmine Guevara was found burned alive in the trunk of her car in Hanson County, SD.
- Diaz, 15, and Salgado were located in Molina’s residence and later transported to Mitchell Police Department for questioning.
- Diaz provided numerous false details about her identity, family, and origins during early interviews.
- Diaz was questioned for several hours, with Miranda warnings given in English and then in Spanish; the questioning included a lengthy Spanish-language exchange to confirm understanding.
- Diaz confessed around 5:30 p.m. after the officers learned Diaz’s true identity, age, and that she might be a witness or participant in Jasmine’s death.
- The trial court suppressed Diaz’s confession, and the State appealed, arguing Diaz knowingly and intelligently waived her Miranda rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Diaz knowingly and intelligently waive Miranda rights? | Diaz argues waiver was not knowing or intelligent. | State contends warnings and conduct show a valid waiver under totality of circumstances. | Waiver found; confession admissible under totality of circumstances |
| Did police misrepresent or minimize Diaz’s rights and thus undermine waiver? | Diaz asserts prefatory remarks and misstatements tainted waiver. | State argues misstatements were improper but not coercive or dispositive. | Misstatements insufficient to invalidate waiver; warnings viewed as a whole were understood |
| Did parental notification/consent failures weigh against a valid waiver? | Diaz contends delays and statutes violated undermining voluntariness. | State argues delays were oversights rather than purposeful coercion; consent issues were not required for interrogation. | Statutory noncompliance weighed against waiver but did not negate it under totality of circumstances |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (defines knowing and intelligent waiver requires awareness of rights and consequences)
- Fare v. Michael C., 442 U.S. 707 (1979) (totality of circumstances for juvenile interrogations)
- Moran v. Burbine, 475 U.S. 412 (1986) (waiver may be inferred from understanding and conduct seeking to waive rights)
- Rhines v. State, Rhines, 1996 S.D. 55 (1996) (requirements for warnings conveyed and the emphasis on totality of circumstances)
- State v. Horse, 2002 S.D. 47 (2002) (juvenile protections; consult with adult before questioning as a factor)
- In re J.M.J., 2007 S.D. 1 (2007) (special care for juveniles in analyzing voluntariness)