State v. Martin
2012 WI 96
| Wis. | 2012Background
- Martin was convicted by jury on two counts: felon in possession of a firearm (Wis. Stat. 941.29(2)) and carrying a concealed weapon (Wis. Stat. 941.23).
- Prior to trial, Martin moved to suppress statements made at the scene; the circuit court denied suppression.
- Police obtained Martin’s statements after arrest and during custodial interrogation without Miranda warnings.
- The State introduced those statements at trial and relied on them to prove ownership/possession of the revolver.
- The court of appeals concluded no Miranda violation occurred; this Court granted review.
- This opinion holds that there was a Miranda violation and the error was not harmless as to the felon-in-possession conviction, requiring reversal and remand for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a Miranda violation during custodial questioning? | Martin | State | Yes, Miranda warning required (custody + interrogation) and warnings were not given. |
| Was the Miranda-error reversible or harmless for the felon-in-possession conviction? | Martin | State | Not harmless beyond a reasonable doubt for felon-in-possession; reversal and remand for new trial. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (require warnings before custodial interrogation)
- Neder v. United States, 527 U.S. 1 (1999) (harmless-error standard for most constitutional errors)
- Harvey v. State, 254 Wis.2d 442 (2002) (state-specific harmless-error framework, burden on state)
- Berke mer v. McCarty, 468 U.S. 420 (1984) (custody triggers Miranda rarity of noncustodial stops)
- Thompson v. Keohane, 516 U.S. 99 (1995) (custody determination factors; coercive atmosphere)