State v. Vigne

Summary

The Supreme Court of Louisiana held that the State failed to establish that the defendant knowingly and voluntarily waived his Miranda rights before making an inculpatory statement identifying the location of narcotics. The court also held that the State did not prove by a preponderance of the evidence that the narcotics would inevitably have been discovered during execution of the search warrant. The court reversed the court of appeal and upheld suppression of the evidence.

Holdings

1. The State failed to prove that defendant knowingly and voluntarily waived his Miranda rights before making the inculpatory statement identifying the location of the narcotics.
2. The inevitable-discovery exception did not permit admission of the narcotics because the State failed to prove by a preponderance of the evidence that the officers would have discovered them through lawful means absent defendant's statement.

Questions Presented

1. Whether the State proved that defendant was adequately advised of his Miranda rights and knowingly and voluntarily waived those rights before making the inculpatory statement identifying the location of the narcotics.
2. Whether narcotics discovered as a result of defendant's statement were admissible under the inevitable-discovery exception to the exclusionary rule.

Disposition

reversed