Deviney v. State

Summary

The Florida Supreme Court reviewed Randall T. Deviney's conviction and death sentence for the first-degree murder of Delores Futrell. The court addressed whether Deviney's confession was obtained after he unequivocally invoked his right to remain silent and concluded that the trial court erred in denying his suppression motion, requiring reversal and remand for a new trial.

Holdings

1. Deviney unequivocally invoked his right to remain silent and terminate the interrogation through his repeated statements that he was done, his request to go home, and his attempts to leave the interview room.
2. Police violated Deviney's right to remain silent by continuing the interrogation after his unequivocal invocation, detaining him, threatening physical restraint, and failing to re-administer Miranda warnings. The resulting confessions were products of compulsion and improper influences and were not shown to be voluntary by competent, substantial evidence.
3. Admission of Deviney's confessions was harmful error because the State failed to prove beyond a reasonable doubt that the error did not contribute to the conviction or death recommendation.

Questions Presented

1. Whether Deviney unequivocally invoked his right to remain silent and end questioning.
2. Whether police violated Miranda by continuing to question Deviney after that invocation, including after taking him into custody without re-administering Miranda warnings.
3. Whether Deviney's confessions to the police and his mother were involuntary and whether admission of the confessions was harmless beyond a reasonable doubt.

Disposition

reversed_and_remanded