State v. Donald, 325 Conn. 346

Summary

The Connecticut Supreme Court considered whether a defendant’s signed confession should be suppressed because police questioned him about a robbery while he was in custody before providing Miranda warnings. The court held that, even assuming the initial questioning was custodial interrogation, the later warnings were sufficiently separated from the initial questioning to make the subsequent waiver and written confession admissible, and it affirmed the judgment.

Holdings

1. The record was adequate for review because the material facts were undisputed and the suppression issue was subject to plenary review, even though the trial court did not issue a written decision or articulate its factual and legal basis for denying suppression.
2. The trial court properly denied the motion to suppress the defendant's written confession because the later Miranda warnings were effective under the circumstances and the defendant's waiver and confession were voluntary.
3. The court declined to decide whether the detective's question at Keney Park constituted custodial interrogation requiring Miranda warnings; assuming that the statement should have been suppressed, any error was harmless beyond a reasonable doubt.

Questions Presented

1. Whether the record was adequate for appellate review despite the trial court's oral denial of the suppression motion without factual findings or an articulated legal basis.
2. Whether the defendant's written confession was inadmissible because it followed a brief unwarned custodial questioning at Keney Park and the later Miranda warnings were ineffective.
3. Whether any error in admitting testimony concerning the defendant's brief statement at Keney Park was harmless.

Disposition

affirmed