State v. Pierce
1610003829
Del. Super. Ct.Oct 2, 2017Background
- Victim Heather Stamper was found murdered on July 9, 2016; Steven Pierce (Defendant) had been involved with her.
- Defendant was interviewed by Delaware State Police detectives on July 10, 2016 and was read Miranda warnings at the start.
- Defendant initially waived Miranda and agreed to speak, but mid-interview he twice requested an attorney (stating “I need to speak to an attorney” and later “I want an attorney” multiple times).
- Detectives continued questioning after the first and second requests for counsel instead of immediately stopping the interview.
- Defendant moved to suppress the entire interview (including for impeachment) on the ground his Miranda and Edwards rights were violated; the State conceded post-invocation statements must be suppressed from the case-in-chief but argued pre-invocation statements were admissible and the whole statement was admissible for impeachment.
- The court ruled pre-invocation statements admissible in the State’s case-in-chief; statements after the first invocation inadmissible in the case-in-chief; but the entire interview admissible for impeachment if Defendant testifies inconsistently.
Issues
| Issue | State's Argument | Pierce's Argument | Held |
|---|---|---|---|
| Whether statements after Defendant invoked right to counsel are admissible in the State’s case-in-chief | Post-invocation statements must be suppressed for case-in-chief (Detectives violated Miranda/Edwards) | All statements should be suppressed (including impeachment) because rights were violated | Suppressed for case-in-chief: any statements after first invocation are inadmissible |
| Whether statements made before invocation are admissible in the State’s case-in-chief | Pre-invocation statements were voluntarily and validly waived and are admissible | Those statements should be excluded because subsequent Miranda violation taints entire interview | Admissible for case-in-chief: pre-invocation statements may be used |
| Whether the Miranda/Edwards violation bars use of the whole statement for impeachment if Defendant testifies inconsistently | Entire statement is admissible for impeachment despite Miranda violation if statement is trustworthy | Entire statement should be barred from impeachment as fruit of violation | Entire interview admissible for impeachment if Defendant testifies inconsistently (trustworthiness standard met) |
| Whether the post-invocation Miranda violation automatically makes the statement untrustworthy | Violation does not automatically render statement involuntary or untrustworthy; voluntariness and interrogation context control | Violation undermines trustworthiness; thus impeachment use should be barred | Violation alone does not make statement untrustworthy; court found statement sufficiently trustworthy for impeachment use |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings and waiver requirements)
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (police must cease interrogation after invocation of right to counsel)
- Harris v. New York, 401 U.S. 222 (U.S. 1971) (statements inadmissible in case-in-chief may be used to impeach defendant)
- Holder v. State, 692 A.2d 882 (Del. 1997) (Delaware recognizes Harris impeachment rule post-Miranda)
- Hill v. State, 316 A.2d 557 (Del. 1974) (voluntariness is key to admissibility)
- DeJesus v. State, 655 A.2d 1180 (Del. 1995) (factors for voluntariness: tactics, interrogation details, defendant characteristics)
- Foraker v. State, 394 A.2d 208 (Del. 1978) (absence of coercion and defendant characteristics support trustworthiness for impeachment)