State v. Fields

265 Conn. 184 (2003) · Supreme Court of Connecticut · August 5, 2003

Summary

The Connecticut Supreme Court affirmed Donald Fields's convictions for felony murder, attempted robbery in the first degree, and conspiracy to commit robbery in the first degree. The court addressed whether his confession was involuntary because of alleged police-inflicted injuries and whether police scrupulously honored his right to remain silent under Michigan v. Mosley. The court also considered a challenge to the state's final argument.

Holdings

  1. No broad federal due process presumption arises merely because a defendant who confessed sustained a physical injury while in police custody. The defendant must establish that police physical violence caused the confession; the court declined to require the state automatically to explain every injury or prove by clear and convincing evidence that the injury was not inflicted to obtain the confession.
  2. The trial court properly denied suppression because its finding that police did not use physical violence to coerce Fields's confessions was not clearly erroneous.
  3. The police scrupulously honored Fields's right to remain silent under Michigan v. Mosley, and the confessions were not subject to suppression on that ground.
  4. The state's challenged final arguments did not warrant reversal. Any improper suggestion that the confession was reliable because a judge admitted it, or any comment concerning the absence of evidence of police coercion, was cured by the trial court's clear and forceful instructions; the remaining challenged arguments did not constitute prosecutorial misconduct.

Questions Presented

  1. Whether the trial court improperly denied suppression of Fields's confessions because the state failed to prove that they were voluntary after Fields sustained injuries while in police custody.
  2. Whether the state was required to rebut, by clear and convincing evidence, a presumption that injuries sustained in police custody caused a confession to be involuntary.
  3. Whether the police failed to scrupulously honor Fields's right to remain silent under Miranda and Michigan v. Mosley by making repeated attempts to question him about the same crime.
  4. Whether the state's final rebuttal argument deprived Fields of a fair trial by improperly relying on the admission of the confession, commenting on his failure to testify, arguing facts not in evidence, or commenting on his prior refusals to speak.

Disposition

affirmed

Cases Cited (32)

  • State v. Toste, 198 Conn. 573, 576, 504 A.2d 1036 (1986)(followed)
  • State v. Pinder, 250 Conn. 385, 418-21, 736 A.2d 857 (1999)(followed)
  • Stein v. New York, 346 U.S. 156, 182, 73 S. Ct. 1077, 97 L. Ed. 1522 (1953)(followed)
  • Jackson v. Denno, 378 U.S. 368, 84 S. Ct. 1774, 12 L. Ed. 2d 908 (1964)(followed)
  • Miller v. Fenton, 796 F.2d 598, 604 (3d Cir. 1986), cert. denied, 479 U.S. 989 (1986)(followed)
  • Cooper v. Scroggy, 845 F.2d 1385, 1390 (6th Cir. 1988)(followed)
  • United States v. Jenkins, 938 F.2d 934, 938 (9th Cir. 1991)(followed)
  • Sims v. Georgia, 389 U.S. 404, 406, 88 S. Ct. 523, 19 L. Ed. 2d 634 (1967)(distinguished)
  • Smith v. State, 254 Ark. 538, 541-42, 494 S.W.2d 489 (1973)(distinguished)
  • People v. Wilson, 116 Ill. 2d 29, 506 N.E.2d 571 (1987)(not followed)

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