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317 Conn. 19
Conn.
2015
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Background

  • Early morning of Oct. 4, 2011: victim Linda Graveline was found stabbed to death in her apartment; neighbors reported seeing defendant Wilfredo Ramos covered in blood and holding a knife.
  • Ramos called police twice alleging injury and mentioning a third party; officers tracked him by cell phone and located him covered in blood.
  • Officers handcuffed Ramos for transport, removed cuffs on arrival, and placed him in a detective bureau interview room; he was not shackled while interviewed.
  • Before Miranda warnings, officers asked whether he was hurt/needed medical attention and “what happened to you?” Ramos said, “I stabbed myself.”
  • Detectives later read Miranda warnings; Ramos orally acknowledged understanding and twice gave detailed inculpatory statements describing stabbing the victim.
  • Trial court held a suppression hearing; it found pre‑Miranda questions were welfare inquiries (not interrogation) and that all statements were voluntary; convictions for murder and evidence tampering followed.

Issues

Issue Plaintiff's Argument (State) Defendant's Argument (Ramos) Held
Whether pre‑Miranda questioning constituted custodial interrogation requiring suppression Questions were routine safety/medical inquiries, not intended or reasonably likely to elicit incriminating responses Officers knew witnesses had identified Ramos and saw him covered in blood; asking “what happened to you?” was reasonably likely to elicit an incriminating response Court held questions were welfare‑oriented, not interrogation; suppression denied
Whether post‑Miranda statements were coerced/ involuntary Ramos knowingly, voluntarily waived Miranda twice and gave calm, uncoerced confessions; no deprivation or physical coercion shown Ramos was physically weakened, interrogated for five hours in a windowless room without food/water/ counsel, rendering confession involuntary Court found confession voluntary under totality of circumstances; suppression denied

Key Cases Cited

  • Miranda v. Arizona, 384 U.S. 436 (establishing custodial‑interrogation warning requirements)
  • Missouri v. Seibert, 542 U.S. 600 (describing "question‑first" post‑Miranda waiver analysis)
  • State v. Canady, 297 Conn. 322 (defining interrogation as police words/actions reasonably likely to elicit incriminating response)
  • State v. Jackson, 304 Conn. 383 (discussing voluntariness standard and totality of circumstances)
  • State v. Jenkins, 298 Conn. 209 (standard of review for suppression findings)
Read the full case

Case Details

Case Name: State v. Ramos
Court Name: Supreme Court of Connecticut
Date Published: May 26, 2015
Citations: 317 Conn. 19; 114 A.3d 1202; SC19188
Docket Number: SC19188
Court Abbreviation: Conn.
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    State v. Ramos, 317 Conn. 19