State v. Monaco

Summary

The Oregon Supreme Court affirmed convictions for two counts of felony murder. The court held that the defendant’s statements during a police interrogation were voluntary under the totality of the circumstances and admissible, and 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 finding that Monaco's statements were voluntary and that his free will was not overborne by improper threats or inducements. The statements therefore were admissible under Oregon law and the Oregon and United States Constitutions.
2. ORS 163.115(1)(b), as interpreted in State v. Blair, does not violate due process by conclusively presuming a material element or shifting the burden of proof. The statute substitutes proof of the culpable mental state required for the predicate felony for a separate culpable mental state concerning causation of death.

Questions Presented

1. Whether the trial court erred in denying suppression of Monaco's interrogation statements on the ground that they were involuntary under ORS 136.425, Article I, section 12, of the Oregon Constitution, and the Fifth and Fourteenth Amendments to the United States Constitution.
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 concerning causation of death or by creating an unconstitutional strict-liability felony-murder offense.

Disposition

affirmed