State of Maine v. Emery

CourtSuperior Court of Maine
DecidedApril 26, 2001
DocketKNOcr-99-428
StatusUnpublished

This text of State of Maine v. Emery (State of Maine v. Emery) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Maine v. Emery, (Me. Super. Ct. 2001).

Opinion

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STATE OF MAINE

v. DECISION AND ORDER

ON MOTION TO SUPPRESS MALCOLM H. EMERY,

Defendant

This matter is before the court on the defendant’s motion to suppress statements he made to a police officer, Det. Sgt. William Donnelly of the Rockland Police Department. The State opposes the motion, so a testimonial hearing was

conducted and post-hearing memoranda have been submitted. The motion is therefore i in . order for disposition.

Det. Donnelly interviewed the defendant seven times about a suspected arson of an unoccupied dwelling which had occurred near the defendant’s home in the early morning of September 24, 1999. The defendant seeks to suppress the content of all these statements arguing that they were either involuntarily made or that, in two instances, the statements were elicited in violation of Miranda requirements.

For purposes of the analysis to be applied to these seven interviews, they can be assigned to three factual categories: one interview at the fire scene, four later interviews before the arrest, and two custodial interviews at the Knox County Jail.

When a defendant makes a claim asserting his statements to the police were

involuntary, it is the State’s burden to establish the contrary beyond a reasonable doubt before the challenged statements may be admitted as evidence at trial. State v. Cole, 1997 ME 112,,J 6, 695 A.2d 1180, 1182.

Addressing the interview at the fire scene first, it is clear that nothing about the circumstances of this conversation between Det. Donnelly and the defendant suggest either a custodial situation or that the statements the defendant made were involuntary. This conversation was brief, informal and friendly. Indeed, it appears that the defendant was interviewed by Det. Donnelly on this occasion, not because he was a suspect, but because he was a potential witness to the fire who lived next door and had called the public safety authorities to respond. That the interview was conducted in Det. Donnelly’s police cruiser is of little import. The interview occurred in the early morning at the fire scene and few other places for private conversation were likely available. No reasonable person in this circumstance would have believed himself to be in police custody or in any way constrained by the officer. State v. Powell, 640 A.2d 609, 610 (Me. 1994).

The next four interviews occurred later on the same day and on October 18, 20 and 28, 1999. These require a somewhat different analysis in that they were more formalized exchanges of somewhat longer duration. However, as the defendant apparently concedes, none of these interrogations were custodial. That is to say, as noted infra, a reasonable person in the defendant’s position would not have believed he was in police custody on these four occasions, “and constrained to a degree associated with formal arrest.” Powell, id. As such, it was not necessary for

Det. Donnelly to have provided the defendant with the Miranda warnings or to have secured from him a waiver of his Fifth and Sixth Amendment rights. State v. Carr, 1997 ME 221, 10, 704 A.2d 353, 356.

Nevertheless, the defendant claims his statements during these interviews were not voluntarily provided because Det. Donnelly induced them by misleading the defendant about his rights. The transcripts of the interviews on these occasions, however, show that Det. Donnelly never misled the defendant about his right to remain silent or to have the assistance of counsel during the interviews. Indeed, not only were these topics not discussed, the defendant demonstrated an awareness that his conversations with Det. Donnelly entailed the risk of self-incrimination. State’s Exhibit 4, p.1. Instead, Det. Donnelly throughout these conversations promoted the theory, which he apparently did not believe to be true, that the fire was probably an accident, that the defendant started it inadvertently, and that he

therefore could not or would not be charged with an accidental fire.! The transcripts

and the testimony at hearing do not specifically address why Det. Donnelly took this approach, but it is fair to infer that he did so as a tactic designed to have the defendant acknowledge some role in the fire. The tactic was a success, and the defendant on three of these occasions orally or in writing acknowledged that he may

have started the fire accidentally by throwing a cigarette at the house while he was

intoxicated.

1 The transcript of the seventh interview, State’s Exhibit 8, p. 17, makes it plain that Det. Donnelly believed that the defendant intentionally set the fire.

3 The defendant argues that this deceptive approach violated his due process rights in that the statements were elicited from him contrary to the government’s . responsibility to act with “fundamental fairness” because it engaged in conduct which “offend{ed] the community’s sense of justice, decency and fair play.” State v. Stade, 683 A.2d 164, 166 (Me. 1996). In support of this argument, he cites the court to

the case of State v. McConkie, 2000 ME 158, 7¥ 9-10, A.2d in which

our Law Court reversed the decision of a trial court which had denied a motion to suppress a statement given to an officer after the officer had assured the suspect that the “interview would stay confidential.” Jd. 4 4. Under such circumstances, the court held, it was a denial of due process to have affirmatively misled the suspect to believe the exact opposite of what was true about his right to remain silent and not incriminate himself, namely that his statement would not be used against him because it was confidential.

While the defendant in the case at bar may have been misled by the detective as to the latter’s beliefs about the nature of the fire and the former’s role in it, the defendant was always correctly told that if the fire were accidentally set there was no

crime, that arson required an intentional act,” and that if all the defendant did was

carelessly toss a cigarette at a house with no intent to damage or burn it, he could not be successfully charged with arson. Indeed, the fact that the defendant has admitted to Det. Donnelly that he may have started the fire in question by accident

advances the prosecution’s cause only modestly, absent other evidence that he

2 Arson requires proof of intentional conduct. State v. Barrett, 408 A.2d 1273, 1276 (Me. 1979).

4 started the fire intentionally. Importantly, then, unlike the facts in McConkie, id., this defendant was not misled in these interviews about either his constitutional . rights or the law.

Moreover, all of these conversations took place in noncustodial circumstances in a cooperative, non-confrontational atmosphere. During these conversations, the defendant was, as noted, alert to the risk of self-incrimination. That he accepted, unwisely perhaps, the detective’s entreaties about the possibility that he set the fire accidentally, does not render his statements inadmissible. That is because if a statement were made unwisely, or based on illogical reasoning, or in the mistaken belief it might assist one’s situation, the law will not by virtue of such miscalculations exclude such a statement as involuntary. State v. Hutchinson, 597 A.2d 1344, 1346 (Me. 1991).

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
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United States v. Jose v. Andrade, Jr.
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United States v. Ronald E. Schwensow
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Phillip Brown v. Paul Caspari, Superintendent
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State v. McConkie
2000 ME 158 (Supreme Judicial Court of Maine, 2000)
State v. Hutchinson
597 A.2d 1344 (Supreme Judicial Court of Maine, 1991)
State v. Carr
1997 ME 221 (Supreme Judicial Court of Maine, 1997)
State v. Cole
1997 ME 112 (Supreme Judicial Court of Maine, 1997)
State v. Smith
615 A.2d 1162 (Supreme Judicial Court of Maine, 1992)
State v. Lavoie
562 A.2d 146 (Supreme Judicial Court of Maine, 1989)
State v. Snow
513 A.2d 274 (Supreme Judicial Court of Maine, 1986)
State v. Barrett
408 A.2d 1273 (Supreme Judicial Court of Maine, 1979)
State v. Rossignol
627 A.2d 524 (Supreme Judicial Court of Maine, 1993)
State v. Caouette
446 A.2d 1120 (Supreme Judicial Court of Maine, 1982)
State v. Collins
297 A.2d 620 (Supreme Judicial Court of Maine, 1972)
State v. Stade
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City of Danbury v. Hovi
640 A.2d 609 (Connecticut Appellate Court, 1994)

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State of Maine v. Emery, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-emery-mesuperct-2001.