People v. Griffin

145 N.W.2d 414, 4 Mich. App. 604, 1966 Mich. App. LEXIS 585
CourtMichigan Court of Appeals
DecidedOctober 25, 1966
DocketDocket 930
StatusPublished
Cited by9 cases

This text of 145 N.W.2d 414 (People v. Griffin) 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 v. Griffin, 145 N.W.2d 414, 4 Mich. App. 604, 1966 Mich. App. LEXIS 585 (Mich. Ct. App. 1966).

Opinion

Holbrook, J.

On November 18, 1964, four officers of the Detroit police department responded to a .complaint that defendant had stolen some paint. *606 On the basis of the description given by the complainant, three of the officers pursued the defendant, arrested him and returned to the scene of the crime. One of the officers remained at the scene taking information, and upon the return of the defendant with the other officers, this officer questioned the defendant concerning the stolen paint. The defendant admitted taking the paint. Such admission was made only a few minutes after defendant’s arrest. The officer at no time advised the defendant of his constitutional right to remain silent. There was no direct evidence that the defendant’s admission was the result of any physical or psychological coercion.

The matter came to trial in the recorder’s court on March 17, 1965, before Judge Arthur J. Koscinski, on a charge of violation of CL 1948, § 750.356a (Stat Ann 1954 Rev § 28.588[1]). At this time in the absence of the jury, the defendant, by his attorney, requested that his admission to the officer be excluded from evidence. The request was based on the failure of the officers to inform defendant of his constitutional right to remain silent. No claim of involuntariness was made. The judge determined that the statement was not the result of undue coercion and further concluded that such conversation was part of the res gestae. The officer’s testimony was heard by the jury at a later time.

Defendant has appealed and presents the following two questions for review: (1) Whether the introduction into evidence of an arresting police officer’s testimony of an inculpatory statement made to such officer by the accused at or near the scene of the crime, without the accused first being informed of his constitutional right to remain silent, voids a conviction based on such testimony. (2) Whether such evidence is admissible as part of the res gestae.

On June 13,1966, the Supreme Court of the United States in the case of Miranda v. Arizona (1966), 384 *607 US 436 (86 S Ct 1602, 16 L ed 2d 694, 10 ALR3d 974), significantly clarified the rules concerning admissibility into evidence of inculpatory statements by tbe accused. Tbe Court held at p 478.

“When an individual is taken into custody or otherwise deprived of his freedom by the authorities and is subjected to questioning, the privilege against self-incrimination is jeopardized. Procedural safeguards must be employed to protect the privilege, and unless other fully effective means are adopted to notify the person of his right of silence and to assure that the exercise of the right will be scrupulously honored, the following measures are required. He must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires. Opportunity to exercise these rights must be afforded to him throughout the interrogation. After such warnings have been given, and such opportunity afforded him, the individual may knowingly and intelligently waive these rights and agree to answer questions or make a statement. But unless and until such warnings and waiver are demonstrated by the prosecution at trial, no evidence obtained as a result of interrogation can be used against him.”

Although the Miranda decision, if applied, would probably invalidate the appellant’s conviction, it was held by the Supreme Court on June 20, 1966, in the case of Johnson v. New Jersey (1966), 384 US 719 (86 S Ct 1772, 16 L ed 2d 882), that the guidelines set forth in Miranda are available only to persons whose trials began after June 13, 1966. Since appellant’s trial began on November 17,1964/Miranda clearly does not apply.

*608 The J ohms on decision also stated that the Court’s holding in Escobedo v. Illinois (1964), 378 US 478 (84 S Ct 1758, 12 L ed 2d 977), was to be available only to those defendants whose trials commenced after June 22, 1964. The Escobedo decision, therefore, is applicable to the instant case.

The Escobedo decision has engendered considerable debate as to its precise holding. The Court in Johnson, however*, has seemed to clarify the meaning of Escobedo. The Court at p 733 states:

“Apart from its broad implications, the precise holding of Escobedo was that statements elicited by the police during an interrogation may not be used against the accused at a criminal trial, ‘[where] the investigation is no longer a general inquiry into an unsolved crime but has begun to focus on a particular suspect, the suspect has been taken into police custody, the police carry out a process of interrogations that lends itself to eliciting incriminating statements, the suspect has requested and been denied an opportunity to consult with his lawyer, and the police have not effectively warned him of his absolute constitutional right to remain silent.’ ” (Emphasis supplied.)

Limited to this precise holding, it is clear that the Escobedo decision, also, is not applicable to the present case for the defendant at no time during the questioning requested and was denied an opportunity to consult with his lawyer. The Escobedo decision thus seems to be limited to its pertinent facts — i.e., where the accused during interrogation had repeatedly asked to speak to his lawyer and such request was denied. That Escobedo does not stand for the general proposition that the failure to advise a defendant of his right to remain silent is fatal to admission of inculpatory statements is made clear by this further quotation from the Johnson opinion at p 733:

*609 “We recognize that certain State courts have perceived the implications of Escobedo and have therefore anticipated our holding in Miranda. Of course, States are still entirely free to effectuate under their own law stricter standards than those we have laid down and to apply those standards in a broader range of cases than is required by this decision.” (Emphasis supplied.)

Michigan has not interpreted the Escobedo decision insofar as it involves the necessity of a warning as to silence by arresting officers. Since Escobedo, by its own terms, does not invalidate the instant conviction and since there is no Michigan authority for so holding, the present conviction should stand.

Supporting this conclusion is the recent Michigan Supreme Court case of People v. Fordyce (1966), 378 Mich 208.

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Related

People v. Meyer
208 N.W.2d 230 (Michigan Court of Appeals, 1973)
People v. Whisenant
172 N.W.2d 524 (Michigan Court of Appeals, 1969)
People v. Hosack
168 N.W.2d 443 (Michigan Court of Appeals, 1969)
People v. Green
151 N.W.2d 834 (Michigan Court of Appeals, 1967)
People v. Castelli
151 N.W.2d 203 (Michigan Court of Appeals, 1967)
People v. Robbins
150 N.W.2d 175 (Michigan Court of Appeals, 1967)
People v. Lewis
149 N.W.2d 457 (Michigan Court of Appeals, 1967)
Commonwealth v. Morrissey
222 N.E.2d 755 (Massachusetts Supreme Judicial Court, 1967)

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Bluebook (online)
145 N.W.2d 414, 4 Mich. App. 604, 1966 Mich. App. LEXIS 585, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-griffin-michctapp-1966.