State v. King

Summary

The document concerns whether a stipulation made during a prior judicial disciplinary proceeding constituted a confession subject to suppression in a subsequent criminal prosecution. The opinions discuss Louisiana confession statutes, the voluntariness requirement, and the protection against compelled self-incrimination under Garrity v. New Jersey. The dissenting justices would have remanded for an evidentiary hearing regarding whether the stipulation was coerced by the threat of removal or other disciplinary sanctions.

Holdings

1. The stipulation could constitute a confession because it acknowledged that King intentionally made false sworn statements and included legal conclusions and intent-related admissions, rather than merely reciting facts from which guilt might be inferred.
2. The district court erred by denying the suppression motion without an evidentiary hearing because King's allegations were sufficient to require factual inquiry into the nature and voluntariness of the stipulation.
3. The alleged threat that refusal to cooperate could result in increased disciplinary sanctions or removal from office was sufficient to warrant an evidentiary inquiry into whether the stipulation was involuntary under Garrity.

Questions Presented

1. Whether the disciplinary stipulation constituted a confession rather than merely an admission of facts tending to establish guilt under La. Rev. Stat. 15:449.
2. Whether the stipulation was subject to suppression as an involuntary statement under La. Rev. Stat. 15:451 and Garrity v. State.
3. Whether the defendant alleged sufficient facts to require an evidentiary hearing on the motion to suppress under La. C. Cr. P. art. 703(E)(1).

Disposition

reversed_and_remanded