Summary
The Supreme Court of Arkansas affirmed Brian Winston’s convictions for two counts of capital murder and two counts of aggravated robbery. The court held that Winston’s custodial statements were voluntary despite the alleged promise of assistance by an investigator and that officers had probable cause to arrest him without a warrant. The court also concluded that no prejudicial error appeared in the record.
Topics
Practice areas
Questions Presented
- Whether Winston's custodial statements were involuntary because he was not adequately advised of his rights before the second statement and because an investigator allegedly promised to help him if he confessed.
- Whether Winston's warrantless arrest was invalid for lack of probable cause and required suppression of evidence or reversal of his convictions.
Holdings
- The trial court properly denied Winston's motion to suppress because the State established that his statements were voluntarily, knowingly, and intelligently given, and the alleged statement that an investigator would "go to bat" for him did not require suppression under the totality of the circumstances.
- The trial court properly found that Winston was validly arrested without a warrant because the officers had reasonable cause, or probable cause, to believe that he had committed a felony.
Key quotations
“If a police official makes a false promise which misleads a prisoner, and the prisoner gives a confession because of that false promise, then the confession has not been voluntarily, knowingly and intelligently made.” (131 S.W.3d at 336)
“Moreover, it is well settled law that an illegal arrest does not void a subsequent conviction.” (131 S.W.3d at 338)
Factual background
Kimberly Amos and Karen Stiles were murdered at a Pizza Hut in West Helena, and money and checks were taken. Winston, an employee and the last person seen at the restaurant, was arrested without a warrant after his girlfriend gave police a gun and reported that Winston had told her to hide it. After receiving and waiving his Miranda rights, Winston initially gave an exculpatory account, but during an unrecorded interval investigators allegedly said they would "go to bat" for him; he then made inculpatory statements that were later recorded or written down.
Procedural history
A Phillips County jury convicted Winston of two counts of capital murder and two counts of aggravated robbery. The trial court imposed concurrent sentences of life without parole for each capital-murder conviction and life imprisonment for each aggravated-robbery conviction, denied Winston's suppression motion, and entered judgment. The Arkansas Supreme Court affirmed.