State v. Harris

562 P.3d 1001
CourtSupreme Court of Kansas
DecidedJanuary 31, 2025
Docket125936
StatusPublished

This text of 562 P.3d 1001 (State v. Harris) is published on Counsel Stack Legal Research, covering Supreme Court of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Harris, 562 P.3d 1001 (kan 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF KANSAS

No. 125,936

STATE OF KANSAS, Appellee,

v.

ROBERT LEE HARRIS JR., Appellant.

SYLLABUS BY THE COURT

1. The privilege against self-incrimination under the Fifth Amendment to the United States Constitution applies only when the accused is compelled to make a testimonial communication that is incriminating.

2. The procedural safeguards adopted by the United States Supreme Court in Miranda v. Arizona, 384 U.S. 436, 467, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966), protect individuals from the inherent compulsions of the interrogation process.

3. A statement is not compelled under the Fifth Amendment if an individual voluntarily, knowingly, and intelligently waives the constitutional privilege against self- incrimination. Without a Miranda advisory, however, a suspect's unwarned statement during custodial interrogation is presumed to be compelled and therefore involuntary.

1 4. If a suspect waived the constitutional rights explained in an earlier Miranda warning, the question of whether a renewed Miranda warning is required at the start of a new questioning session boils down to whether—considering the totality of the circumstances—the suspect continues to understand and voluntarily waives the constitutional rights explained in the initial Miranda warning.

5. Even when police have complied with the procedural safeguards of Miranda, a defendant's statement to the police may still be involuntary, and therefore inadmissible, if it was extracted by impermissible government coercion.

6. Coercive police tactics fall into two broad categories: those that are inherently coercive, resulting in a per se violation of the Due Process Clause, and those that are coercive under the circumstances given the nature of the interrogation and the unique traits of the individual suspect.

7. Advising an accused that officers can obtain an order compelling fingerprint access or the passcode to unlock a cell phone is not inherently coercive if officers have a reasonable basis to believe that a court will issue such an order.

8. Analysis of coercion based on the nature of the interrogation and the unique traits of the individual suspect requires courts to assess the totality of the circumstances to determine whether the suspect's statement was a voluntary act of free and independent will or the result of impermissible coercion that overcame the suspect's rational intellect and free will.

2 Appeal from Johnson District Court; NEIL B. FOTH, judge. Oral argument held September 10, 2024. Opinion filed January 31, 2025. Affirmed.

Michael P. Whalen, of Law Office of Michael P. Whalen, argued the cause and was on the briefs for appellant.

Kendall S. Kaut, assistant district attorney, argued the cause, and Sommer Mackay, assistant district attorney, Stephen M. Howe, district attorney, and Kris W. Kobach, attorney general, were on the brief for appellee.

The opinion of the court was delivered by

STANDRIDGE, J.: A jury convicted Robert Lee Harris Jr. of first-degree premeditated murder of his wife. On direct appeal, he challenges the district court's denial of his motion to suppress evidence retrieved from his locked cell phones. Specifically, he argues law enforcement obtained the passcodes necessary to unlock the cell phones in violation of his Fifth Amendment privilege against self-incrimination. But substantial competent evidence supports the district court's finding—based on its assessment of the totality of the circumstances—that law enforcement did not compel Harris to involuntarily make incriminating statements against his will. First, the initial Miranda warning given to Harris was still effective and his prior Miranda waiver had not expired when the detective asked him to provide the passcodes, so there is no presumption that Harris was compelled to involuntarily disclose them. Second, the detective who requested the passcodes had a reasonable basis to believe a court would issue an order to compel fingerprint access or the passcodes to open the phones when the detective informed Harris that he could obtain such an order, so this statement was not inherently coercive. Third, when we consider the totality of the circumstances, including the detective's statement, other interrogation details, and the individual characteristics of Harris as the accused, we are not persuaded Harris involuntarily provided the passcodes due to impermissible government coercion. Thus, the district court did not err by denying Harris' motion to suppress the evidence obtained from the search of the phones.

3 FACTS

On January 8, 2018, Overland Park police responded to Harris' residence after a neighbor reported a disturbance from Harris' apartment, including hearing loud noises and a woman call out, "[H]elp me." The neighbor testified he saw Harris drag a large, heavy trash can down the apartment stairs to his wife's SUV and was concerned there could be a body in the trash can. While waiting for the police to arrive, the neighbor saw Harris make several trips to the dumpster while carrying smaller white trash bags.

Officers made contact with Harris at his apartment. After some discussion, Harris allowed officers into the apartment so they could determine whether there was an injured person inside. They found no one else in the apartment but noted broken glass on the floor and reddish-pink stains on the carpet in the dining/living room area. The officers ran a records check on Harris and discovered he had an outstanding warrant for his arrest.

Several hours later, Harris called 911 and reported his wife missing. The same officers from the previous call responded to his apartment, and Harris agreed to speak to them. Inside the apartment, officers noticed a rug that was previously in the living room had been moved to the dining room to cover the red stains they saw earlier. Harris admitted to moving the rug and eventually gave consent for officers to swab the stains to test for human blood. Officers also noted the smell of bleach inside the apartment, and Harris told them he had been cleaning.

The officers asked Harris to come outside to the patrol car to fill out paperwork regarding a missing person, including consent to search forms. Harris agreed. While in the patrol car, Harris used his cell phone several times. Officers asked Harris if he would go to a different location to speak with detectives. Harris initially agreed but then changed his mind. At that point, officers arrested Harris for the outstanding warrant. In a

4 search incident to the arrest, officers found two cell phones in Harris' pockets, among other items.

Officers transported Harris to the Tomahawk Ridge police station, where he was held for questioning overnight and interviewed for several hours by Detectives Erin Johnson and Marcus Meyer. Before asking any questions, Detective Meyer read Harris the Miranda warning advising Harris of his constitutional rights. Video footage shows Harris seated in an interview room, wearing leg shackles but no handcuffs. Harris said he understood his rights and agreed to answer some questions.

The first interview lasted approximately one and a half hours, at which point Harris invoked his right to remain silent. Detectives stopped asking questions at that time and left the room. They told Harris to knock on the door if he changed his mind. Less than 10 minutes later, Harris knocked on the door and asked to speak with the detectives. When they reentered, Harris asked how it worked to get an attorney. Detective Meyer explained the court would appoint one after Harris was arraigned.

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Bluebook (online)
562 P.3d 1001, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-harris-kan-2025.