State v. Lavaris

649 P.2d 849, 32 Wash. App. 769, 1982 Wash. App. LEXIS 3137
CourtCourt of Appeals of Washington
DecidedAugust 16, 1982
Docket10378-4-I
StatusPublished
Cited by4 cases

This text of 649 P.2d 849 (State v. Lavaris) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Lavaris, 649 P.2d 849, 32 Wash. App. 769, 1982 Wash. App. LEXIS 3137 (Wash. Ct. App. 1982).

Opinions

Williams, J.

Luis M. Lavaris was accused of first degree murder and found guilty as charged in a trial to the court with a jury. He appeals from the judgment entered on the verdict raising issues concerning the admission of his confession, references to a polygraph test and hearsay evidence. We affirm.

Luis Lavaris, Francisco Castro and the victim were at Betty Haro's apartment in Seattle on the evening of July 8, 1980. In the course of the evening, the victim and Haro fell asleep. Haro awoke to find Lavaris and Castro standing over the victim's wounded body. Lavaris had stabbed the victim several times with a large knife, causing his death. Castro was convicted of first degree murder by a jury on October 10, 1980, for his participation in the crime.

Several months after the incident, Lavaris was arrested in Oregon and extradited to Washington, being placed in the King County Jail. On February 19, 1981, at about 2 p.m., Detectives Gruber and Crawford of the Seattle Police Department met Lavaris in the reception area of the jail, their intention being to take him to their office across the street to talk about the murder if Lavaris wished to do so. According to one of the detectives, when this was explained to Lavaris, he stated right off that:

It was right at that time that Mr. Lavaris said that he was willing to talk to us. He stated right off that he didn't want somebody else getting in trouble for something he did; referring to Mr. Castro.

The two detectives and Lavaris then went to the office where they waited for almost an hour for an interpreter. Although the detectives determined that Lavaris could [771]*771speak and understand English, they believed that the administration of rights should be done in both English and Spanish, and the interview conducted in both languages also. Miranda1 and constitutional rights were explained when the interpreter arrived about 3 p.m. Lav-aris then gave a complete account of the murder, his report being reduced to writing and acknowledged as correct 4 days later.

At a pretrial suppression hearing, the court decided that the State had not shown by a preponderance of the evidence that the statements Lavaris made before being advised of his rights were spontaneous and, hence, were inadmissible. The court suppressed anything Lavaris said before 3 p.m. but declared admissible everything he said thereafter.

The first issue is whether the conditions that rendered the prewarning statements inadmissible carried over to invalidate Lavaris' subsequent confession. United States v. Toral, 536 F.2d 893 (9th Cir. 1976).

Application of the principle that an intervening Miranda warning may not insulate a subsequent confession from the taint of prior unwarned interrogation caused reversal in State v. Erho, 77 Wn.2d 553, 463 P.2d 779 (1970). The situation and decision of the court is stated in the opinion as follows:

Here, the trial court found, and we agree, that the warning which the officer testified was given at the time of arrest was inadequate. State v. Tetzlaff, 75 Wn.2d 649, 453 P.2d 638 (1969). It failed to advise the appellant that anything he said might be used against him and that, being an indigent, he was entitled to appointed counsel if he so desired prior to any questioning. Despite these inadequacies, however, the officers in the patrol car questioned him and elicited an admission of his participation in the offense involved. This was later, within a very short time and without a break in continuity, reduced to written form. As heretofore indicated, the trial court [772]*772excluded the oral admissions but admitted the written statement.
We are satisfied, upon the record as it stands, that the written statement is but the direct and derivative product of the oral admissions. It perforce suffers from the same infirmities the trial court found infected the oral statements. In short, by his oral admissions the appellant had "let the cat out of the bag by confessing" and was not "thereafter free of the psychological and practical disadvantages of having confessed." He could not get the cat back in the bag, for the secret was out. United States v. Bayer, 331 U.S. 532, 91 L. Ed. 1654, 67 S. Ct. 1394 (1947); Westover v. United States, 384 U.S. 436, 494, 16 L. Ed. 2d 694, 86 S. Ct. 1602 (1966); Harrison v. United States, 392 U.S. 219, 20 L. Ed. 2d 1047, 88 S. Ct. 2008 (1968). Thus, the voluntariness and admissibility of his written statement was compromised.

State v. Erho, at 560-61. In this case the evidence is that at the very outset Lavaris volunteered that he was the murderer. The account of what followed is given in the testimony of Detective Gruber:

Q [By defense counsel] Was there any reason that you could not have waited for [the interpreter] to come over before you started questioning [Lavaris] about the incident?
A Well, you would have to understand the tone of the whole meeting. Mr. Lavaris was very eager to talk about the incident.
Q And you were very eager to question him, were you not?
A Mr. Lavaris did way more talking than I did questioning.
Q Was there any reason why you could not have waited until [the interpreter] came over at three o'clock before you started taking down a statement in a case of that serious nature?
A I didn't take any notes at all during that . . . conversation. It was strictly sitting there and basically talking.
Q My question, Officer, was whether or not you could have waited for [the interpreter]. That would not have posed any hardship to you.
A No, it wouldn't have.
[773]*773Q Now, did Mr. Lavaris indicate to you a time or two that he didn't want to talk to you any more?
A No.
Q He never indicated that to you?
A No.
Q Before [the interpreter] had a chance to advise Mr. Lavaris of his rights, Mr. Lavaris, I take it, had pretty much confessed to this murder; is that correct?
A Yes; to me. Officer Crawford wasn't present.

The detective further testified:

Q [By the prosecutor] Was it your intent to question the defendant [Lavaris] before he was advised of his constitutional rights?
A No, not before.
Q You mean in the jail, that's what you were speaking of, right before he waived his constitutional rights; apparently he made statements to you admitting certain facts about the incident, is that correct?
A That's correct.

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Related

State v. Lavaris
721 P.2d 515 (Washington Supreme Court, 1986)
State v. Lavaris
649 P.2d 849 (Court of Appeals of Washington, 1982)

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Bluebook (online)
649 P.2d 849, 32 Wash. App. 769, 1982 Wash. App. LEXIS 3137, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lavaris-washctapp-1982.