State v. Williams
15 A.3d 753
| Me. | 2011Background
- On June 5, 2009, a Maine State Police trooper went to Williams's residence and asked to talk inside his cruiser.
- The cruiser was parked in Williams's driveway, with the trooper's dog behind animal cages in the cruiser.
- The trooper advised Williams he was not under arrest but did not advise Miranda rights.
- During the hour-long interrogation, Williams admitted some sexual conduct with the child but denied a specific act.
- Williams moved to suppress the statements, the court denied, Williams was tried and convicted, and the conviction was appealed on the custody issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Williams in custody during the interrogation? | Williams argues he was in custody. | State contends he was not in custody. | Not in custody; interrogation was non-custodial. |
Key Cases Cited
- State v. Poblete, 2010 ME 37 (2010) (custody analysis; mixed fact/law with de novo review)
- State v. Nadeau, 2010 ME 71 (2010) (ten-factor custody test for custodial interrogation)
- State v. Dion, 2007 ME 87 (2007) (Miranda rights required for custodial interrogation)
- State v. Dumas, 2010 ME 57 (2010) (competent evidence supports trial findings)