State v. Jackson
120 So. 3d 88
Fla. Dist. Ct. App.2013Background
- Jarvis Jackson, serving a federal 15-year sentence, requested and initiated a prison interview with local investigators seeking a Rule 35 sentence reduction by providing information about a CVS shooting.
- Investigators (a detective, a sergeant, and an ATF agent) interviewed Jackson at the Federal Detention Center; no Miranda warning was required because Jackson invited the meeting.
- After investigators told Jackson his CVS information was not new, questioning shifted to two homicide matters in which Jackson was a suspect; investigators told him they could not promise a sentence reduction and identified the U.S. Attorney/judge as decision-makers.
- Investigators said substantial assistance would be needed for any sentence reduction and used phrases like “you gotta give to get,” but made no explicit promise of leniency or immunity.
- Jackson made inculpatory statements implicating himself and was later charged in multiple homicide and firearm counts; he moved to suppress those statements as involuntary due to an alleged unlawful promise.
- The trial court granted suppression finding an impermissible quid pro quo; the State appealed and this opinion reverses suppression, concluding no coercive promise was made.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jackson's statements were involuntary due to promises by investigators | Jackson: investigators’ comments (e.g., “you gotta give to get”) amounted to an unlawful quid pro quo and rendered the confession involuntary | State: Jackson initiated the interview; investigators clearly disclaimed authority to grant leniency and made no binding promises—statements therefore voluntary | Reversed: investigators’ remarks did not constitute coercive, improper promises; statements admissible |
| Whether investigators’ statements improperly induced confession by offering leniency | Jackson: investigators induced confession by implying a trade for sentence reduction | State: investigators expressly stated they could not guarantee relief and would only pass info to U.S. Attorney; no shield from prosecution promised | Reversed: no promise of leniency or immunity sufficient to overcome free will |
| Applicability of Day and Ramirez to suppression analysis | Jackson relied on Day and Ramirez as precedent finding confessions involuntary where promises were implied | State argued facts differ: Jackson volunteered interview and was told limits of investigators’ authority | Court: Day and Ramirez inapplicable—material factual distinctions; investigators unequivocally disclaimed decision-making authority |
| Standard of review for voluntariness and factual findings | Jackson: trial court’s factual findings entitled to deference; voluntariness is mixed question | State: appellate review is de novo for coercion legal issue though factual findings presumed correct | Court: affirmed standard—facts presumed but legal determination reviewed de novo; concluded no coercion |
Key Cases Cited
- Connor v. State, 803 So.2d 598 (Fla. 2001) (standard of review: factual findings presumptively correct; mixed law–fact reviewed independently)
- Baker v. State, 71 So.3d 802 (Fla. 2011) (confession inadmissible if coerced; coercive police conduct must overcome free will)
- Schoenwetter v. State, 931 So.2d 857 (Fla. 2006) (voluntariness requires absence of coercive police conduct)
- Johnson v. State, 696 So.2d 326 (Fla. 1997) (statements after promises may be inadmissible in some circumstances)
- Blake v. State, 972 So.2d 839 (Fla. 2007) (questions implying promises not per se improper; not automatically render statements inadmissible)
- Maqueira v. State, 588 So.2d 221 (Fla. 1991) (officer’s offers to help admissible where officer disclaims authority to make promises)
- United States v. Davidson, 768 F.2d 1266 (11th Cir. 1985) (confession voluntary where agent said he could not promise relief but cooperation could lead to prosecutorial recommendation)
- State v. Carroll, 103 So.3d 929 (Fla. 2d DCA 2012) (detective’s “see what we can do to help” not a binding promise of leniency)
- Day v. State, 29 So.3d 1178 (Fla. 4th DCA 2010) (example cited by trial court where promises rendered confession involuntary)
- Ramirez v. State, 15 So.3d 852 (Fla. 1st DCA 2009) (another case cited by trial court supporting suppression where implied promises existed)