YOUVENS MADEUS v. STATE OF FLORIDA
244 So. 3d 1095
| Fla. Dist. Ct. App. | 2018Background
- Appellant Youvens Madeus was arrested and charged with first-degree murder of his girlfriend; DNA and medical examiner testimony linked a machete wound to the victim’s death.
- Shortly after arrest, police read Miranda warnings; appellant acknowledged understanding each right.
- Detective asked if appellant was willing to talk; appellant replied, “About certain things, yes,” and later reiterated willingness to “talk about certain things.”
- Appellant moved to suppress post-arrest statements arguing his reply was an ambiguous/equivocal response—not a valid waiver of Miranda rights.
- Trial court denied suppression; jury heard interrogation in which appellant admitted fighting with victim and swinging a machete but denied intent to hit her.
- Appellant was convicted; on appeal the Fourth District reviewed whether the reply constituted an unambiguous, selective waiver of Miranda rights.
Issues
| Issue | Appellant's Argument | State's Argument | Held |
|---|---|---|---|
| Whether appellant’s reply “about certain things” was an ambiguous/equivocal response that required clarification before questioning. | The phrase was ambiguous/equivocal and did not constitute a valid waiver of the right to remain silent; police should have clarified scope before questioning. | The phrase was a clear, selective waiver—appellant agreed to answer some subjects but not others—so no further clarification was required. | The court held the reply was an unequivocal, selective waiver of Miranda rights; no further inquiry was required and denial of suppression affirmed. |
Key Cases Cited
- State v. Weiss, 935 So. 2d 110 (Fla. 4th DCA 2006) (standard of review for suppression rulings)
- Alvarez v. State, 15 So. 3d 738 (Fla. 4th DCA 2009) (ambiguous waiver must be clarified before initial questioning)
- Michigan v. Mosley, 423 U.S. 96 (1975) (suspect may control subjects and timing of questioning)
- Gonzalez v. State, 136 So. 3d 1125 (Fla. 2014) (refusal to answer several questions is not invocation of right to remain silent)
- United States v. Eaton, 890 F.2d 511 (1st Cir. 1989) (waiver not equivocal where suspect says he will answer some questions)
- Bruni v. Lewis, 847 F.2d 561 (9th Cir. 1988) (suspect’s conditional willingness to answer constitutes selective waiver)