State v. Robinson
1411017691A&B
| Del. Super. Ct. | Apr 11, 2017Background
- Defendant Jacquez Robinson is charged with murder; trial set for July 11, 2017.
- Prison staff seized a drawing from Robinson’s cell that contained apparent gang symbols/mottos.
- Robinson moved to suppress (a) the drawing seized from his cell and (b) statements he made on a pre-printed Security Threat Group/Offender Screening Work Sheet during prison intake.
- The drawing suppression motion was briefed by defendant only; the court found it ripe to decide without a State response.
- The intake form asked about gang membership and related safety issues; Robinson identified himself as a TMG gang member.
- The court denied suppression of the drawing and deferred ruling on the intake-statement issue, ordering briefing on whether Miranda or the routine booking exception applies and offering an evidentiary hearing if requested.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of drawing seized from prison cell | State: seizure lawful; drawing relevant | Robinson: suppression due to Fourth Amendment violation | Denied — prisoner has no reasonable expectation of privacy in cell; Hudson governs |
| Admissibility of statements on intake screening form | State: statements routine booking/booking exception applies for safety/biographical questions | Robinson: statements made in custody required Miranda warnings | Deferred — record inadequate; court orders simultaneous briefing on custody and booking-exception applicability; possible evidentiary hearing if needed |
Key Cases Cited
- Rakas v. Illinois, 439 U.S. 128 (1978) (Fourth Amendment expectation-of-privacy framework)
- Hudson v. Palmer, 468 U.S. 517 (1984) (prisoners lack Fourth Amendment privacy expectation in cells)
- Minnesota v. Carter, 525 U.S. 83 (1998) (analysis of reasonable expectation of privacy)
- Howes v. Fields, 565 U.S. 499 (2012) (incarceration alone does not automatically create Miranda custody)
- United States v. Bishop, 66 F.3d 569 (3d Cir. 1995) (recognizing routine booking exception to Miranda)
- United States v. Horton, 873 F.2d 180 (8th Cir. 1989) (routine booking exception applied to biographical booking questions)
- People v. Elizalde, 351 P.3d 1010 (Cal. 2015) (holding questions about gang affiliation exceed the booking exception)