State v. Figueroa, 146 A.3d 427

April–May 2015: Figueroa arrested on drug charges, transported to Somerset County jail; received Miranda warnings at booking and invoked right to counsel. Counsel was appointed April 15.
While in custody Figueroa repeatedly told jail staff he wanted to speak with DEA Agent Kelly Hooper; his attorney spoke with Hooper and said he could not attend but did not object to a recorded interview.
On May 1, Agent Hooper interviewed Figueroa alone, recorded the interview, and orally advised him of Miranda rights (right to remain silent, that statements can be used in court, right to an attorney, and that one would be appointed if he could not afford one); Hooper also told Figueroa that he had an attorney who had said it was okay to talk.
Hooper did not expressly tell Figueroa he had a right to have counsel physically present during the interview. Figueroa made incriminating statements during the congenial, non-deceptive interview.
Figueroa moved to suppress the May 1 statements; the suppression court found the warnings imperfect but sufficient and found Figueroa voluntarily waived his rights. He pleaded conditional guilty and appealed.

Issue	Plaintiff's Argument (Figueroa)	Defendant's Argument (State)	Held
Whether Miranda warning was defective for failing to expressly state right to have counsel present	Warnings omitted explicit statement that counsel could be present during questioning, so waiver was uninformed	Warnings and surrounding circumstances (appointed counsel’s consent; defendant requested interview) adequately conveyed right to counsel including presence	Court held warnings were adequate; defendant was effectively advised of right to counsel including presence
Whether waiver was knowing, intelligent, and voluntary	Waiver invalid because he lacked full awareness of right abandoned due to incomplete warning	Waiver valid: defendant initiated interview, was told he had counsel and that counsel consented, was warned about use of statements	Court held waiver was knowing and voluntary; statements admissible

Miranda v. Arizona, 384 U.S. 436 (establishing warnings and exclusionary rule)
Dickerson v. United States, 530 U.S. 428 (discussing Miranda's protection against compulsion in custodial interrogation)
Florida v. Powell, 559 U.S. 50 (clarifying that warnings must reasonably convey the substance of Miranda rights)
Duckworth v. Eagan, 492 U.S. 195 (warnings are prophylactic measures, not rights themselves)
California v. Prysock, 453 U.S. 355 (Miranda satisfied by fully effective equivalent language)
Patterson v. Illinois, 487 U.S. 285 (use of statements against defendant is the adverse consequence informing the waiver analysis)
State v. Ayers, 433 A.2d 356 (Me. 1981) (Miranda requires intelligible conveyance of substance of right to counsel)
State v. Lockhart, 830 A.2d 433 (Me. 2003) (standard of review for Miranda suppression rulings)
State v. Marden, 673 A.2d 1304 (Me. 1996) (State bears burden to prove warnings and valid waiver)