Williams v. State
128 A.3d 30
| Md. | 2015Background
- Deandre R. Williams was arrested and interviewed by Prince George’s County detectives about a January 2011 killing; interview was recorded and transcribed.
- Early in the custodial interview Williams said, “I don’t want to say nothing. I don’t know,” while officers were explaining the process and that they would read Miranda rights.
- Officers then read Miranda rights; after further discussion (including contrasting a premeditated murder scenario with a “robbery gone bad” scenario and suggesting different consequences), Williams gave an oral and written confession.
- Williams moved to suppress his statements, arguing (1) his utterance was an invocation of the right to remain silent and officers improperly continued questioning and (2) his statements were involuntary because officers implied confession to a lesser scenario might reduce punishment.
- Trial and Maryland intermediate appellate court denied suppression; Maryland Court of Appeals granted certiorari and affirmed the denial of suppression, holding the utterance was ambiguous and the confession voluntary.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether “I don’t want to say nothing. I don’t know” unambiguously invoked Miranda silence | Williams: phrase was a clear invocation; “I don’t know” continued, not negated, the refusal; officers understood it as refusal | State: the addition “I don’t know” created indecision; objectively ambiguous so officers need not stop | Held: Ambiguous—reasonable officer could interpret it as indecision; not an unambiguous invocation |
| Whether officers’ interruption converted an unambiguous invocation into an ambiguous one | Williams: officers cut him off, which cannot create ambiguity in his clear invocation | State: officers and Williams talked over each other; interruptions reflected attempts to clarify | Held: Interruption did not change the objective ambiguity created by “I don’t know” |
| Whether confession was involuntary under Maryland common law because of implied benefit/threat | Williams: detectives implied he might "see the street again" if he framed it as a robbery gone bad, creating an inducement | State: officers merely described two possible factual/charge scenarios; no promise or improper benefit; Williams did not rely on any promise | Held: No improper inducement; presentation of two scenarios and permissible deception do not render confession involuntary |
| Whether, assuming inducement, Williams relied on it causally in confessing | Williams: relied on officers’ characterization when confessing | State: Williams’s own statements show he expected severe punishment regardless (e.g., “they’re going to smoke my boots anyway”) | Held: No causal nexus shown; Williams did not rely on any promised benefit; confession voluntary |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial suspects must be warned of right to remain silent and counsel)
- Berghuis v. Thompkins, 560 U.S. 370 (2010) (invocation of Miranda rights must be unambiguous; silence alone is insufficient)
- Davis v. United States, 512 U.S. 452 (1994) (ambiguous or equivocal requests for counsel do not require cessation or clarification by police)
- Ballard v. State, 420 Md. 480 (2011) (colloquial requests for counsel can be unambiguous; context matters)
- Williams v. State, 219 Md. App. 295 (2014) (intermediate appellate decision affirming suppression denial; held addition of “I don’t know” rendered statement ambiguous)
- Hillard v. State, 286 Md. 145 (1979) (Maryland two‑pronged test for involuntariness by inducement: (1) threat/promise by police and (2) causal reliance)
- Ball v. State, 347 Md. 156 (1997) (police presentation of alternative characterizations/scenarios is permissible deception and does not necessarily render confession involuntary)