State of Connecticut v. Alberto Garcia, 299 Conn. 39

Summary

The Supreme Court of Connecticut affirmed Alberto Garcia's convictions for first-degree robbery and conspiracy to commit first-degree robbery. The court upheld the denial of his motion to suppress a written statement, concluding that the statement was made knowingly, intelligently, and voluntarily after Miranda warnings, and that the statement was properly authenticated despite being translated and recorded by a bilingual police officer.

Holdings

1. Even assuming Garcia was in custody when he gave his statement, suppression was not required because he had been advised of his Miranda rights and had voluntarily waived them.
2. The trial court properly determined that Garcia's statement was knowingly, intelligently, and voluntarily made and was not the product of police coercion.
3. A written confession from a Spanish-speaking defendant may be authenticated through testimony from the bilingual police officer who personally heard the statement, translated it, reduced it to writing, and identified the document as the defendant's statement; an impartial or certified interpreter is not categorically required.
4. The admission of Garcia's confession did not violate equal protection because non-English-speaking persons and deaf persons are not necessarily similarly situated, and Garcia failed to establish either a cognizable equal protection violation or resulting harm warranting suppression.

Questions Presented

1. Whether Garcia was in police custody when he made his written statement and, if so, whether the statement was inadmissible despite the Miranda warnings and waiver.
2. Whether Garcia's written confession was knowingly, intelligently, and voluntarily made or was the product of police coercion.
3. Whether the confession was properly authenticated when it was translated and written in English by a bilingual police officer rather than by a disinterested certified interpreter.
4. Whether admitting the confession violated equal protection because the translating officer did not possess the certifications required for interpreters serving deaf or hearing-impaired persons under General Statutes § 46a-33a (e).

Disposition

affirmed