State v. Nightingale

58 A.3d 1057 (Me. 2012) · Supreme Judicial Court of Maine · November 29, 2012

Summary

The Maine Supreme Judicial Court affirmed Nathaneal K. Nightingale's convictions for murder and manslaughter. The court held that Nightingale was not in custody during the initial nine-hour polygraph-related interrogation, that the fourteen-day rule from Maryland v. Shatzer did not apply, and that the subsequent in-home statements and physical evidence were properly admitted. The court also concluded that the police did not deliberately employ an impermissible two-step interrogation strategy and that the confession was voluntary.

Holdings

  1. Nightingale was not in custody for Miranda purposes during the interrogation at the Criminal Investigation Division.
  2. Maryland v. Shatzer's fourteen-day waiting period did not apply because Nightingale invoked his right to counsel during a noncustodial interrogation.
  3. The State proved that the detectives did not deliberately employ a two-step interrogation strategy to undermine Miranda, so Nightingale's post-warning statements were admissible.
  4. The post-warning statements were voluntary under the totality of the circumstances despite the detectives' use of fabricated evidence during the earlier interrogation.
  5. The physical evidence was admissible because it was obtained as a result of voluntary post-warning statements.

Questions Presented

  1. Whether Nightingale was in custody for Miranda purposes during the polygraph-related interrogation.
  2. Whether Maryland v. Shatzer's fourteen-day waiting period applied when police reinitiated questioning after Nightingale requested counsel during a noncustodial interrogation.
  3. Whether the detectives deliberately employed a two-step interrogation procedure that rendered Nightingale's post-warning statements inadmissible under Missouri v. Seibert.
  4. Whether police deception during the earlier interrogation rendered Nightingale's later post-warning statements involuntary.
  5. Whether physical evidence obtained as a result of the post-warning statements was inadmissible as fruit of constitutional violations.

Disposition

affirmed

Cases Cited (17)

  • Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966)(followed)
  • State v. Gould, 2012 ME 60, ¶ 11, 43 A.3d 952(followed)
  • State v. Poblete, 2010 ME 37, ¶ 22, 993 A.2d 1104(followed)
  • State v. Bridges, 2003 ME 103, ¶¶ 35-36, 829 A.2d 247(distinguished)
  • State v. Michaud, 1998 ME 251, ¶ 4, 724 A.2d 1222(followed)
  • Maryland v. Shatzer, 559 U.S. 98, 130 S. Ct. 1213, 175 L. Ed. 2d 1045 (2010)(followed)
  • McNeil v. Wisconsin, 501 U.S. 171, 182 n.3, 111 S. Ct. 2204, 115 L. Ed. 2d 158 (1991)(followed)
  • State v. Lavoie, 562 A.2d 146, 149-50 (Me. 1989)(followed)
  • Oregon v. Elstad, 470 U.S. 298, 105 S. Ct. 1285, 84 L. Ed. 2d 222 (1985)(followed)
  • Missouri v. Seibert, 542 U.S. 600, 124 S. Ct. 2601, 159 L. Ed. 2d 643 (2004)(followed)

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