State v. Gunnar Liam Breymann
Background
- Police responded to a reported burglary at Breymann’s parents’ home and observed meth paraphernalia in the backyard; father suspected his 19‑year‑old son, Gunnar Breymann.
- Five days later an officer encountered Breymann, questioned him about drugs and the burglary, and Breymann admitted to some marijuana use and initially denied consent to search his bedroom.
- At the house the officer handcuffed Breymann (stating he was detained while obtaining a warrant), questioned him further, and Breymann made pre‑Miranda admissions about meth paraphernalia; he later said “you can go search my room right now.”
- The officer then read Miranda rights, gave a written consent form, and Breymann executed it; a subsequent search of his bedroom uncovered meth and related paraphernalia.
- Breymann was charged with possession of methamphetamine; he moved to suppress the pre‑ and post‑Miranda statements and evidence from the warrantless search, and the district court granted suppression.
- The State appealed; the Idaho Court of Appeals reviewed voluntariness (totality of circumstances) and reversed the suppression order, holding the statements and consent were voluntary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Breymann’s pre‑Miranda confession was involuntary | State: confession was voluntary under totality; limited, noncoercive questioning | Breymann: absence of Miranda, youth, emotional distress, repeated questioning overbore will | Court: confession voluntary; factors (age, duration, demeanor) did not show coercion despite lack of Miranda |
| Whether Breymann’s post‑Miranda waiver was knowing and voluntary | State: Miranda administered and waiver valid under totality | Breymann: emotional fragility and intense questioning prevented a knowing waiver | Court: waiver was voluntary, knowing, intelligent; brief detention and prior Miranda experience weigh for State |
| Whether consent to search bedroom was voluntary | State: consent freely given (initial refusal, later voluntary consent, mother present, daytime, choice to seek warrant) | Breymann: consent was result of duress/coercion from detention and pressure to consent | Court: consent voluntary under Schneckloth totality; officer’s suggestion of warrant did not coerce consent |
| Whether suppression remedy was appropriate | State: suppression improper because statements/consent admissible | Breymann: suppression proper because evidence tainted by involuntary statements and coerced consent | Court: reversed suppression; evidence and statements admissible; remanded for proceedings |
Key Cases Cited
- Miller v. Fenton, 474 U.S. 104 (1985) (involuntary confession analysis under Due Process)
- Haynes v. Washington, 373 U.S. 503 (1963) (confessions obtained by coercion inadmissible)
- Colorado v. Connelly, 479 U.S. 157 (1986) (coercive police activity is necessary predicate for involuntary confession)
- Arizona v. Fulminante, 499 U.S. 279 (1991) (totality of circumstances test for voluntariness)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (voluntariness of consent searches evaluated under totality of circumstances)
- Missouri v. Seibert, 542 U.S. 600 (2004) (Miranda warnings’ presence is significant in voluntariness analysis)
- New York v. Quarles, 467 U.S. 649 (1984) (failure to give Miranda warnings does not alone render a confession involuntary)
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warning of rights)
- Oregon v. Elstad, 470 U.S. 298 (1985) (initial unwarned admission does not necessarily taint subsequent warned confession)
- Coolidge v. New Hampshire, 403 U.S. 443 (1971) (warrantless searches presumptively unreasonable)