State v. Medina
155 A.3d 285
| Conn. App. Ct. | 2017Background
- On January 1, 2011, defendant Jose E. Medina participated in a vehicle chase and shooting that resulted in two deaths; he was later arrested after a separate police pursuit and transported to Hartford PD major crimes division.
- Medina arrived at the major crimes division around 4:55 p.m.; he signed a Miranda waiver form at 6:35 p.m.
- Between arrival and booking, detectives interviewed Medina (including Detective Luis Poma); at one point he requested and, with police present, spoke by phone to Kasandra Rivera and admitted shooting the victims.
- The timing of the Miranda warnings/waiver relative to (a) Poma’s interrogation and (b) the phone call to Kasandra is unclear from the record.
- Medina was convicted by a jury of capital felony and conspiracy to commit murder; the court sentenced him to life without release and additional consecutive terms, then vacated lesser murder convictions per precedent.
- On appeal Medina argued (1) admission of inculpatory statements violated Miranda because warnings occurred after custodial interrogation, and (2) any waiver was not knowing/voluntary because he was under PCP; he did not raise these issues at trial and invoked Golding review.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Medina) | Held |
|---|---|---|---|
| Were inculpatory statements admitted despite lack of Miranda warnings, violating Miranda? | Record is inadequate to show violation; trial record lacks findings; Golding not satisfied. | Detectives interrogated Medina before advising/waving Miranda; his prewaiver statements were admitted in violation of Miranda. | Court: Record inadequate to determine timing of warnings vs. statements; Golding first-prong failed; claim not reviewable. |
| Was Medina’s Miranda waiver involuntary/unknowing due to PCP intoxication? | State: no clear record or findings; issue was unpreserved and record insufficient. | Medina: under PCP at time of waiver so could not knowingly/voluntarily waive Miranda rights. | Court: No factual findings on intoxication or waiver timing; record insufficient, so issue not reached on appeal. |
| Preservation / Golding review: May unpreserved Miranda claims be raised on appeal? | State: Golding requires adequate record; here record is inadequate. | Medina: despite lack of preservation, Golding allows appellate review of constitutional errors. | Court: Golding not satisfied because record lacks necessary factual findings; appellate review denied. |
| Harmless error analysis applicability to alleged Miranda violation | State: Not reached because record inadequate; no harmless-error analysis conducted. | Medina: If violation occurred, state must show harmlessness beyond a reasonable doubt. | Court: Did not reach harmlessness because threshold Golding/record issues unresolved. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (establishes custodial interrogation warnings and waiver requirements)
- State v. Golding, 213 Conn. 233 (1989) (framework for appellate review of unpreserved constitutional claims)
- State v. Polanco, 308 Conn. 242 (2013) (vacating lesser included convictions when greater offense conviction stands)
- State v. Edmonds, 323 Conn. 34 (2016) (restating Golding four-part test and appellate review standards)
- In re Yasiel R., 317 Conn. 773 (2015) (modification of Golding’s third-prong guidance)
- State v. Burns, 140 Conn. App. 347 (2013) (describing Miranda custody/interrogation thresholds)
- State v. Cushard, 164 Conn. App. 832 (2016) (state bears burden to prove waiver was voluntary, knowing, and intelligent)