State v. Madonda, 375 P.3d 424

Defendant Muziwokuthula Madonda was arrested in Texas on suspicion of two New Mexico murders and transported to the Montgomery County jail.
After arrest, Rangers interviewed Defendant; he said “I will not talk.” Officers later planned a second interrogation and retrieved Defendant’s Bible from his impounded van for use in questioning.
At the start of the March 28 interview, Agent Armijo read Miranda warnings; Defendant said he wanted a lawyer and that he “didn’t have anything to say” (invoking both right to counsel and right to remain silent).
Rather than ending the interrogation, officers displayed Defendant’s Bible and engaged him in conversation about the Bible and “the truth,” repeatedly attempting to get him to waive his rights; Defendant then agreed to talk and gave a statement.
The next morning Defendant made further incriminating statements and ultimately confessed to the murders. Defendant moved to suppress statements from March 28–29; the district court granted suppression, and the State appealed.
The New Mexico Supreme Court affirmed suppression, holding officers failed to “scrupulously honor” Defendant’s invocation of Miranda rights and that both the March 28 and March 29 statements were inadmissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers continued interrogation after Defendant invoked his right to counsel and right to remain silent	Officers ceased interrogation after the invocation; any later talk was initiated by Defendant and was not police conduct likely to elicit an incriminating response	Officers continued interrogation by displaying and using the Bible and by statements designed to elicit statements despite invocation	Held: Officers continued interrogation; showing and using the Bible and persuasive comments were police-initiated conduct reasonably likely to elicit incriminating responses
Whether statements after the invocation must be suppressed, including later statements the next day	Statements were voluntary because Defendant waived rights after being re-advised; later statements therefore admissible	Waiver was the product of impermissible police-initiated interrogation after invocation; because no counsel was provided and no 14-day break in custody occurred, subsequent statements are inadmissible	Held: Suppress all statements after the initial invocation (both March 28 and March 29) because Edwards protections were violated and no counsel/14-day break occurred

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings and interrogation must cease if rights invoked)
Edwards v. Arizona, 451 U.S. 477 (1981) (after request for counsel, further police-initiated interrogation is prohibited absent counsel or valid waiver)
Rhode Island v. Innis, 446 U.S. 291 (1980) ("interrogation" includes words or actions police should know are reasonably likely to elicit incriminating responses)
Michigan v. Mosley, 423 U.S. 96 (1975) (suspect’s invocation must be scrupulously honored; repeated efforts to wear down suspect are impermissible)
McNeil v. Wisconsin, 501 U.S. 171 (1991) (after requesting counsel, suspect may not be approached for further interrogation until counsel is made available)
Maryland v. Shatzer, 559 U.S. 98 (2010) (14-day break in custody may permit re-approach absent counsel)
Smith v. Illinois, 469 U.S. 91 (1984) (Edwards creates bright-line rule to prevent badgering or overreaching)
State v. King, 300 P.3d 732 (N.M. 2013) (officers must "scrupulously honor" a suspect’s invocation of rights)