State v. Spriggs
1 CA-CR 16-0575
| Ariz. Ct. App. | Aug 17, 2017Background
- Spriggs was convicted of armed robbery and aggravated robbery; he also pled guilty to misconduct involving weapons.
- The victim GJ was robbed in a secured parking lot; Spriggs and an accomplice initiated the assault with guns.
- Spriggs’s fingerprints were found in the getaway car; police recovered keys and a blue bandana and gun linked to him.
- Spriggs testified he learned details from others and that his backpack and items were later recovered from him by police.
- The State impeached Spriggs with prior statements to police that he had no knowledge of the robbery, including post-arrest remarks.
- Spriggs argued the impeachment violated his right against post-arrest silence; the trial court allowed it; the appeals court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether impeachment with post-arrest statements violated Miranda/post-arrest silence rules | Spriggs | Spriggs | Impeachment permitted; statements voluntary and contradicted at trial |
Key Cases Cited
- Doyle v. Ohio, 426 U.S. 610 (U.S. 1976) (prohibits comment on post-arrest silence as evidence of guilt)
- State v. Ramirez, 178 Ariz. 116 (Ariz. 1994) (permitting impeachment when statements after Miranda are inconsistent with trial testimony)
- State v. Tuzon, 118 Ariz. 205 (Ariz. 1978) (prior inconsistent statements may be used for impeachment)
- State v. Henderson, 210 Ariz. 561 (Ariz. 2005) (fundamental error standard for appellate review)