Williams v. State
100 A.3d 1208
| Md. Ct. Spec. App. | 2014Background
- Williams was arrested March 30, 2011 in DC for a January 2011 College Park homicide; he was interrogated in a DC homicide unit with two PG County officers present after his arrest.
- Prior to Miranda warnings, Williams stated, I don’t want to say nothing. I don’t know,—, and then was advised of rights and confessed during the interview.
- The suppression motion to suppress the inculpatory statement was denied by the Prince George’s County circuit court; the case proceeded on a not guilty plea on an agreed statement of facts.
- Williams was convicted of first degree murder and use of a handgun in a crime of violence and sentenced to life with most of it suspended plus a concurrent sentence.
- Underlying facts: Williams and Weaver planned a robbery at 8809 38th Ave, College Park; a struggle ensued, Williams shot the victim, and Williams later disposed of the gun; three 10mm casings were recovered from the scene with no direct physical link to Williams.
- Weaver later confessed to conspiring with Williams; an autopsy confirmed multiple gunshot wounds as the cause of death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Williams’ statement invocation of silence unambiguous? | Williams argues the phrase 'I don’t want to say nothing. I don’t know' was an unambiguous invocation. | State argues the invocation was ambiguous and equivocal under Davis/Berghuis standards. | Invocation was ambiguous; interrogation could continue. |
| Was Williams’ confession voluntary under Maryland common law? | Williams contends police induced confession through incentives about outcomes. | State maintains no improper inducement; officers presented two factual theories only and did not promise benefits. | Confession not involuntary; no improper inducement under Hillard. |
Key Cases Cited
- Costley v. State, 175 Md. App. 90 (Md. Ct. App. 2007) (Miranda applicability; invocations before custody; voluntary waiver framework)
- Winder v. State, 362 Md. 275 (Md. 2001) (special consideration and coercion analyses in inducement context)
- Marr v. State, 134 Md. App. 152 (Md. Ct. App. 2000) (custody/interrogation timing for invocation of rights; anticipatory invocation)
- Costley v. State, 175 Md. App. 90 (Md. Ct. App. 2007) (custody-interrogation proximity and invocation timing (duplicate for emphasis))
- Hoerauf v. State, 178 Md. App. 292 (Md. Ct. App. 2008) (pre- and post-invocation circumstances; custody connection to interrogation)
- Ball v. State, 347 Md. 156 (Md. 1997) (permissible police deception; coercion vs. permissible trickery)
- Davis v. United States, 512 U.S. 452 (U.S. 1994) (clarity standard for invoking right to counsel)
- Berghuis v. Thompkins, 560 U.S. 370 (U.S. 2010) (unambiguous invocation required; continuous opportunity to invoke right to silence)
- McNeil v. Wisconsin, 501 U.S. 171 (U.S. 1991) (anticipatory invocation not permitted; interrogation must be imminent)
- Smith v. State, 20 Md. App. 577 (Md. Ct. App. 1974) (non-coercive exhortation does not render confession involuntary)