State v. Gonzalez
25 A.3d 648
| Conn. | 2011Background
- Gonzalez was arrested Oct. 28, 2005 for the murder of Joanne Trautwein and was taken to Stamford police for questioning without Miranda warnings.
- The interview occurred in a small interrogation room; Gonzalez was handcuffed to a chair and told he would be booked and that he could tell his side of the story.
- Guzda stated it was Gonzalez's “opportunity to tell his side,” which the defense argued constituted interrogation; Gonzalez initially invoked counsel and remained silent.
- Guzda encouraged Gonzalez to talk, and Gonzales began narrating regarding his activities on the day of the murder; later questions were asked, leading to a narrated statement.
- Gonzalez moved to suppress the statements; the trial court found some periods of interrogation and suppressed certain clarifying questions; the question of the initial interrogation’s existence remained central.
- The trial court convicted Gonzalez of felony murder, robbery in the first degree, and kidnapping in the first degree; on appeal, the court reversed the conviction for the improperly admitted narration and remanded for a new trial, while also addressing double jeopardy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Suppression of statements due to Miranda/interrogation | State argues no interrogation occurred after invocation and warnings were not required | Gonzalez contends initial questioning was interrogation and warrants suppression | Interrogation occurred; suppression warranted |
| Double jeopardy regarding felony murder and robbery | State asserts Greco allows consecutive punishment for felony murder with robbery | Gonzalez argues same offense against double jeopardy | Not violated; convictions permitted under Greco guidance |
| Salamon instruction on kidnapping conviction | State contends Salamon issue may arise on retrial | Gonzalez challenges jury instruction under Salamon | Court remanded for new trial due to suppression; double jeopardy analysis separately decided; Salamon issue not sustaining exclusion on retrial |
Key Cases Cited
- State v. Mullins, 288 Conn. 345 (2008) (two-step custody/interrogation analysis; suppression standards)
- State v. Kirby, 280 Conn. 399 (2006) (non-interrogation when rights understood; routine questions not interrogation)
- State v. Canales, 281 Conn. 572 (2007) (interrogation ends when suspect invokes rights; scrupulous honoring of invocation)
- Rhode Island v. Innis, 446 U.S. 291 (1980) (functional equivalent of interrogation; focus on suspect perception)
- Oregon v. Elstad, 470 U.S. 298 (1985) (unwarned statements may be followed by voluntary statements; harmless error doctrine limits when applicable)
- Edwards v. Arizona, 451 U.S. 477 (1981) (once a suspect requests counsel, interrogation must cease unless initiated by suspect)
- Miranda v. Arizona, 384 U.S. 436 (1966) (establishes warnings for custodial interrogation)