People of Michigan v. Daren Donell Fenderson

CourtMichigan Court of Appeals
DecidedJune 6, 2024
Docket367926
StatusUnpublished

This text of People of Michigan v. Daren Donell Fenderson (People of Michigan v. Daren Donell Fenderson) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People of Michigan v. Daren Donell Fenderson, (Mich. Ct. App. 2024).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 6, 2024 Plaintiff-Appellant,

v No. 367926 Wayne Circuit Court DAREN DONELL FENDERSON, LC No. 23-000412-01-FC

Defendant-Appellee.

Before: SWARTZLE, P.J., and SERVITTO and GARRETT, JJ.

PER CURIAM.

The victim died during a “hit-and-run,” and defendant voluntarily confessed to the crime after several interviews with the police. The district court admitted defendant’s video confession over his motion to exclude, concluding that defendant had validly waived his right to remain silent and had made a voluntary statement. Viewing the same video, however, the circuit court suppressed the confession, finding instead that police had coerced defendant into make the confession. Our review of the record confirms that the circuit court erred, and we reverse and remand for further proceedings consistent with this opinion.

Defendant was 24-years-old at the time of his arrest, and he had completed three years of high-school education. The police attempted to conduct a custodial interrogation after arresting defendant, but could not proceed because defendant appeared to be intoxicated. The next day, the officers read defendant his constitutional rights concerning the interrogation, and defendant signed a document that explained these rights. During this initial interrogation, defendant told the officers that his truck was carjacked on the night of the victim’s death, and that the carjacker was driving defendant’s vehicle when the victim was killed. The officers interrupted defendant, however, and told defendant that they had surveillance-video footage that showed defendant driving the vehicle. Defendant attempted to change his story, and he agreed to tell the officers “what they wanted to hear” once he had an attorney. Interpreting this as a request for an attorney, the officers left defendant and tried to find him one.

After making several inquiries over a couple of hours, the officers were unsuccessful in finding defendant an attorney. They returned to the interrogation room, and one of the uniformed

-1- officers handcuffed defendant for transport to a detention center. Defendant expressed confusion on being removed from the room, stating, “hold on, wait . . . wait, huh?” One of the officers explained to defendant that they could not find defendant an attorney, and he did not have funds to hire his own attorney, so they were going to return him to the detention center. Defendant questioned why he was leaving, and the officer explained that they could not talk to him because he asked for an attorney and that they would use the statement that defendant had given them earlier. The officer further explained that defendant would be returned to the detention center, and the police and prosecutor would seek an arrest warrant. The officer reiterated that he could not talk to defendant about the case because defendant had asked for an attorney. Defendant then responded, “Uhm, I just want to get this over,” and he repeated this sentiment several more times.

In response, the officer explained to defendant that he did not want defendant to feel “compelled” to speak to them. Defendant asserted that he wanted to speak with the officers. Interpreting this as a request to reinitiate their conversation, the investigating officer left the room, and an officer separate from the investigation instructed defendant again about his constitutional rights. Defendant signed another form indicating that he understood his rights, and he then confessed to hitting the victim with his truck. Defendant was in the interrogation room for over five hours, but only spoke to the officers for two of those hours. When he was not speaking with the officers, defendant received food, drink, and bathroom breaks, and he was free to stand and walk around the room.

Defendant was subsequently arraigned on the charge of first-degree murder, among other charges, and bound over to the circuit court for trial with a bond that would “remain at remand, or no bond.” Defendant moved to suppress his confession and argued that the officers violated his constitutional rights because he was coerced into waiving his right to counsel. The circuit court found that the officers used their inability to locate an attorney for defendant as a scare tactic to coerce defendant into continuing the interrogation. Thus, the circuit court held that defendant’s confession was not voluntary, and it suppressed the statement.

The prosecutor now presents this interlocutory appeal on leave granted. People v Fenderson, unpublished order of the Court of Appeals, entered November 15, 2023 (Docket No. 367926).

“This Court reviews for clear error a trial court’s factual findings in a ruling on a motion to suppress evidence. A trial court’s factual findings are clearly erroneous when this Court is left with a definite and firm conviction that the trial court made a mistake.” People v Clark, 330 Mich App 392, 415; 948 NW2d 604 (2019) (citations omitted). “To the extent that a trial court’s ruling on a motion to suppress involves an interpretation of the law or the application of a constitutional standard to uncontested facts, our review is de novo.” Id. (citation omitted).

The United States Supreme Court has “established procedures designed to safeguard” a defendant’s Fifth Amendment rights. Id. (citing Miranda v Arizona, 384 US 436, 467; 86 S Ct 1602; 16 L Ed 2d 694 (1966)). “[W]hen an officer interrogates a person who is in custody, that person must be informed in clear and unequivocal terms that he has the right to remain silent and that anything that he says can be used against him in court.” Id. (quotation marks and citation omitted). Further, “the right to have counsel present during the interrogation is indispensable to the protection of the Fifth-Amendment right” and, “if [the accused] cannot afford a lawyer, one

-2- will be appointed for him.” Id. at 415-416 (citation omitted). Thus, if the defendant has requested counsel in his dealing with the police, he is not subject to further interrogation (1) until counsel has been made available to him, or (2) unless and until he reinitiates a discussion with police and waives the right to counsel. Id. at 416, 419. Any evidence obtained during an interrogation may not be used against the accused “[u]nless the person in custody has been given the required warnings and still waives his rights.” Id. at 416 (quotation marks and citation omitted). See also Edwards v Arizona, 451 US 477, 484-485; 101 S Ct 1880; 68 L Ed 2d 378 (1981) (explaining that once a defendant has asserted his or her right to counsel, no further interrogation may occur “unless the accused himself initiates further communication, exchanges, or conversations with the police”).

In this case, defendant signed multiple forms that indicated that he understood his constitutional right to counsel. The circuit court found that the officers used their inability to locate an attorney for defendant as a scare tactic that coerced defendant into providing his confession. The prosecutor argues that the circuit court erred because defendant’s confession was voluntary.

All “words or actions on the part of the police” are relevant in determining whether coercive police practices have caused an accused to “elicit an incriminating response.” People v White, 294 Mich App 622, 629; 823 NW2d 118 (2011). “[W]hen a suspect has been afforded Miranda warnings and affirmatively waives his Miranda rights, subsequent incriminating statements may be used against him” if the waiver was “voluntarily, knowingly, and intelligently” made.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Edwards v. Arizona
451 U.S. 477 (Supreme Court, 1981)
People v. Kowalski
584 N.W.2d 613 (Michigan Court of Appeals, 1998)
People v. Adams
627 N.W.2d 623 (Michigan Court of Appeals, 2001)
People v. Tanner
853 N.W.2d 653 (Michigan Supreme Court, 2014)
People v. White
823 N.W.2d 118 (Michigan Court of Appeals, 2011)
People v. Ryan
819 N.W.2d 55 (Michigan Court of Appeals, 2012)

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People of Michigan v. Daren Donell Fenderson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-daren-donell-fenderson-michctapp-2024.