State v. Shawn William Wass
162 Idaho 361
| Idaho | 2017Background
- Late-night patrol: Officer Drake encountered Wass and a passenger near a closed parking area; Wass initially denied having ID and denied illegal items in the car.
- Mobile computer check revealed two outstanding warrants for Wass; during a field sobriety test Wass placed his wallet on the hood and admitted he had lied about ID because of possible warrants.
- Officer Drake placed Wass in restraints and asked again about illegal items; un-Mirandized Wass admitted there were syringes in the vehicle.
- Officer Drake realized he had erred by questioning before Miranda, then immediately read Wass his Miranda rights; Wass waived and again admitted syringes.
- A brief search (after the post-Miranda admission) recovered syringes and drug paraphernalia; one syringe tested positive for methamphetamine.
- Wass moved to suppress the statements and derivative physical evidence; the district court denied suppression, and Wass conditionally pleaded guilty reserving the suppression issue for appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred by denying suppression of Wass’s admission and resulting physical evidence | Post-Miranda warnings cured any prior Miranda error; officer did not deliberately use a two-step interrogation | Initial unwarned admission tainted the subsequent confession and derivative evidence; suppression required | Court affirmed: Seibert inapplicable (no deliberate two-step tactic); Elstad governs; post-Miranda waiver was voluntary and admissible |
Key Cases Cited
- Oregon v. Elstad, 470 U.S. 298 (pre-Miranda voluntary statements do not automatically render subsequent post-Miranda confessions inadmissible)
- Missouri v. Seibert, 542 U.S. 600 (two-stage interrogation designed to evade Miranda can render post-warning confession inadmissible)
- Marks v. United States, 430 U.S. 188 (rule for interpreting fragmented Supreme Court decisions)
- U.S. v. Williams, 435 F.3d 1148 (9th Cir.) (interpreting Seibert to hold Justice Kennedy’s narrower test controls: suppress only where two-step interrogation was deliberate)