State v. Monaco

Summary

The Oregon Supreme Court affirmed convictions for two counts of felony murder arising from a fatal apartment fire. The court held that the defendant’s statements during a police interrogation were voluntary under the totality of the circumstances and were admissible. It also held that Oregon’s felony-murder statute, ORS 163.115(1)(b), as interpreted in State v. Blair, did not violate the Due Process Clause of the Fourteenth Amendment.

Holdings

1. The trial court did not err in denying suppression because, under the totality of the circumstances, Monaco's free will was not overborne and his statements were voluntary under Oregon law and the federal Constitution.
2. ORS 163.115(1)(b), as interpreted in State v. Blair, does not violate due process by creating a burden-shifting or conclusive presumption, and treating felony murder as strict liability in part does not itself establish a due-process violation.

Questions Presented

1. Whether Monaco's custodial statements were involuntary under ORS 136.425, Article I, section 12, of the Oregon Constitution, or the Fifth and Fourteenth Amendments, because police interrogation tactics overbore his will or implied leniency.
2. Whether ORS 163.115(1)(b), as interpreted in State v. Blair, violates the Due Process Clause by conclusively presuming a culpable mental state regarding causation of death or by creating an unconstitutional strict-liability felony-murder offense.

Disposition

affirmed