State v. McAnulty
338 P.3d 653
| Or. | 2014Background
- Jeanette Maples, the defendant's daughter, suffered prolonged abuse, starvation, and physical injuries by the defendant in Oregon; the family moved to Eugene in 2006; Jeanette died in December 2009 after severe abuse and dehydration; detectives interrogated the defendant after Jeanette's death and collected physical evidence from two homes; the defendant pleaded guilty to aggravated murder and tampering, with a penalty-phase trial to determine death sentence; on automatic and direct review, the court addressed the admissibility of statements and various trial rulings while ultimately affirming the death sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pretrial suppression ruling reviewability under ORS 138.012(1)? | State argues review is limited by ORS 138.050/138.222 due to unconditional plea. | McAnulty argues the pretrial ruling is reviewable under ORS 138.012(1) despite not reserving a conditional plea. | Reviewable under ORS 138.012(1); error deemed harmless. |
| Effect of unconditional guilty plea on ability to withdraw under ORS 135.335(3)? | State contends plea waiver prevents withdrawal. | McAnulty contends conditional plea requirements govern withdrawability. | Unconditional plea precludes withdrawal; conviction stands; reviewable for penalty stage. |
| Whether detectives violated right to remain silent by continuing after second/third invocations? | State asserts invocations were equivocal or waiver allowed continued questioning. | Defendant unequivocally invoked right to silence and detectives violated it. | Second and third invocations violated rights; statements from first interrogation suppressed; later interrogations validated as voluntary. |
| Harmlessness of improperly admitted statements from first/second interrogations? | Prosecution asserts evidence supported the death penalty. | Illegally obtained statements were prejudicial and would sway the penalty verdict. | Harmless beyond a reasonable doubt in light of later admissible evidence and guilty plea. |
| Whether trial court properly excused prospective jurors for cause (Howe, Gonzalez, Brown, Thurston)? | No reversible error; court acted within discretion, and jurors’ responses supported excusals. |
Key Cases Cited
- Acremant v. State, 338 Or 302 (Or 2005) (penalty-phase evidence framework in death penalty cases)
- Dinsmore v. State, 342 Or 1 (Or 2006) (review of pretrial rulings when plea entered; waiver considerations)
- Montez v. State, 309 Or 564 (Or 1990) (automatic/direct review distinct from guilty-plea appeals; sentencing considerations)
- Jarnagin v. State, 351 Or 703 (Or 2012) (factors for determining whether later statements stem from initial Miranda violation)
- State v. Davis, 336 Or 19 (Or 2003) (harmless-error standard in state constitutional review; preservation of error)
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (miranda waiver and invocation of rights; voluntariness analysis)
- Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (two-stage interrogation and admissibility of subsequent statements)
- Michigan v. Mosley, 423 U.S. 96 (U.S. 1975) (valid re-initiated interrogation after invocation of rights)