State v. Strozier, 834 N.W.2d 857

Strozier was convicted of second-degree murder and aggravated assault for stabbing two men during an altercation.
He moved to suppress statements made during custodial interrogation; the circuit court denied the motion.
Police read Miranda rights; interrogation began after re-advisement; Strozier waived rights.
Strozier had a closed-head injury, intoxication, sleep deprivation, and received one dose of pain medication before interrogation.
During a two-hour interview, Strozier asserted self-defense and later claimed he returned to the scene to protect himself and seek respect.
The jury rejected Strozier’s self-defense claim and convicted him; on appeal he challenges Miranda waiver and voluntariness and the sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Strozier’s Miranda rights validly waived and his statements voluntary?	Strozier contends waiver/voluntariness were not valid due to head injury, intoxication, sleep deprivation, medication, and coercive atmosphere.	Strozier claims the circumstances prevented a valid waiver and rendered statements involuntary.	Waiver voluntary and statements voluntary.
Was there sufficient evidence to reject Strozier’s self-defense claim?	Evidence showed self-defense could explain the stabbings.	Self-defense warranted conviction if entry into scene was to protect himself.	Sufficient evidence supported rejection of self-defense.

State v. Tuttle, 2002 S.D. 94 (S.D. 2002) (valid Miranda waiver and voluntariness framework; de novo review)
State v. Ralios, 2010 S.D. 43 (S.D. 2010) (totality of circumstances in Miranda waiver and voluntariness)
State v. Aesoph, 2002 S.D. 71 (S.D. 2002) (impact of fatigue on voluntariness; sleep deprivation considerations)
State v. Fisher, 2011 S.D. 74 (S.D. 2011) (six-hour interview; voluntariness considerations)
State v. Tapio, 459 N.W.2d 406 (S.D. 1990) (intoxication and voluntariness of waiver; capacity to understand questions)