State v. Thomas
202 Md. App. 545
Md. Ct. Spec. App.2011Background
- Thomas was charged with multiple counts of sexual offenses involving his daughter; suppression hearing held on the issue of Miranda custody and voluntariness.
- Defense argued Thomas was in custody and not given Miranda warnings; evidence included a transcript and video of his August 31, 2010 statement.
- Interrogation occurred in a child-interview room at a police station; two detectives questioned him for about an hour and a half; room door reportedly unlocked.
- Detectives repeatedly told Thomas he was not under arrest; he drove himself to the station; no weapons were displayed and detectives were in plain clothes.
- Thomas admitted to sexual touching of his daughter; the State later argued questioning aimed to gather evidence, not merely to learn what happened.
- Circuit Court granted suppression on custody ground and declined to rule on voluntariness; this was appealed by the State.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Thomas in Miranda custody during questioning? | State contends he was not in custody; factors show freedom to leave and non-coercive setting. | Thomas argues custodial interrogation existed due to locked door, confinement, and coercive environment. | Custody found to be not established; circuit court erred in suppressing for custody. |
| Should statements be suppressed as involuntary due to inducements? | State seeks ruling on voluntariness; argues no improper inducement affected confession. | Thomas maintains statements were involuntary due to promises to help daughter via officers’ assurances. | Voluntariness issue not addressed on record; Court declines to rule; remanded for factual findings if pursued. |
Key Cases Cited
- Buck v. State, 181 Md.App. 585 (Md. Ct. App. 2008) (one factor in custody is whether suspect is aware of focus of investigation; free to leave if contemporaneous conduct corroborates)
- Abeokuto v. State, 391 Md. 289 (Md. 2006) (not in custody where questioned as potential suspect for ~90 minutes; no coercive coercion shown)
- Owens v. State, 399 Md. 388 (Md. 2007) (totality of circumstances test for custody; lists multiple contributing factors)
- Bond v. State, 142 Md.App. 219 (Md. Ct. App. 2002) (no single factor dispositive; consider totality of circumstances)
- Beheler, 463 U.S. 1125 (U.S. 1983) (Miranda warnings not required solely because questioning occurs in station; custody depends on restraint level)
- J.D.B. v. North Carolina, 131 S. Ct. 2394 (U.S. 2011) (custody is objective; age and perspective matter in liberty to leave)
- State v. Rucker, 374 Md. 199 (Md. 2003) (ultimate inquiry is whether there is a formal arrest or restraint on freedom of movement)
- Smith v. State, 186 Md. App. 498 (Md. 2010) (two-step Miranda framework; custody and interrogation burden on defendant)
- Rush v. State, 403 Md. 68 (Md. 2008) (record must support voluntariness; where record insufficient, cannot review voluntariness)