White v. State, 76 So. 3d 335

Charles White was convicted of two counts of first-degree murder and related crimes after a 1999 double homicide at Mayers' home in Florida.
Evidence showed a damaged back door, a sawed-off shotgun, a bandana, and a mural note referencing violence at Mayers' residence.
DNA from a bandana matched co-defendant Armond Davis, who was tried separately and convicted.
In 2000, White was arrested for marijuana possession; police later questioned him for the murders for about 13 hours without initial probable cause arrest.
Miranda warnings were given during the lengthy interrogation, which culminated in White admitting involvement in the crimes.
White moved to suppress the statements claiming pre-arraignment delay under Rule 3.130, but the trial court denied suppression and the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 3.130 suppression standard justified?	White	White	No automatic suppression; prejudice required to show induced confession
Harmlessness of Postell hearsay flaw	White	State	Harmless error; substantial evidence of guilt outweighed admission
Polygraph reference and mistrial request	White	State	Not reversible; curative instruction sufficient and evidence harmless

Globe v. State, 877 So.2d 663 (Fla. 2004) (prearraignment delay must be shown to induce confession for suppression)
Chavez v. State, 832 So.2d 730 (Fla. 2002) (delay must show induced confession; prejudice required)
Keen v. State, 504 So.2d 396 (Fla. 1987) (delay not per se exclusion; prejudice needed)
Conde v. State, 860 So.2d 930 (Fla. 2003) (case-by-case analysis of delay and voluntariness)
State v. Bennett, 339 S.E.2d 213 (W.Va. 1985) (pretextual arrest delay to obtain confession examined for admissibility)
Persinger v. State, 286 S.E.2d 261 (W.Va. 1982) (delay focus on purpose of obtaining confession)
Wiberg v. Minnesota, 296 N.W.2d 388 (Minn. 1980) (consider reliability, intentional delay, and impact on rights when evaluating delay)