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300 P.3d 732
N.M.
2013
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Background

  • King, held in custody for an aggravated battery charge, was interrogated after Miranda warnings were given; he stated he did not wish to answer “at the moment” due to intoxication; the detective pressed him and obtained an incriminating statement; the district court suppression was granted based on an unambiguous invocation of the right to remain silent; the State appealed to the New Mexico Supreme Court under §39-3-3(B)(2); the court affirms the district court’s suppression ruling.
  • King’s statements and actions showed a clear invocation of the right to remain silent, not a vague hesitation; the detective persisted and coerced, undermining Fifth Amendment protections.
  • The interrogation continued after an unambiguous invocation, violating Mosley’s protection against coercive custodial interrogation after a right to silence is invoked.
  • The district court correctly suppressed the statement; the interrogation was not scrupulously honored after an unambiguous invocation.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether King unambiguously invoked the right to remain silent State contends invocation was equivocal King clearly said not at the moment, showing an unambiguous invocation Yes; King unambiguously invoked the right to remain silent
Whether interrogation was scrupulously honored after invocation Interrogation continued despite invocation Detective acted within duty after invocation No; interrogation was not scrupulously honored; statements suppressed

Key Cases Cited

  • Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes warning and rights; right to silence must be honored once invoked)
  • Berghuis v. Thompkins, 560 U.S. 370 (2010) (unambiguous invocation required to halt questioning)
  • Michigan v. Mosley, 423 U.S. 96 (1975) (interrogation must cease upon unambiguous invocation; cannot coerce continuation)
  • State v. Guerra, 278 P.3d 1031 (2012-NMSC-014) (recognizes no requirement to state a reason for invoking rights; no implied waiver)
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Case Details

Case Name: State v. King
Court Name: New Mexico Supreme Court
Date Published: Apr 15, 2013
Citations: 300 P.3d 732; 4 N.M. 17; 2013 NMSC 014; 2013 NMSC 14; Docket 33,395
Docket Number: Docket 33,395
Court Abbreviation: N.M.
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    State v. King, 300 P.3d 732