State v. Jeremy Lambert

Summary

The Vermont Supreme Court affirmed Jeremy Lambert’s convictions on two counts of sexual assault against a minor. The court held that Lambert was not in custody during questioning by detectives and therefore was not entitled to Miranda warnings, and that his statements were voluntary. The court also reviewed his unpreserved challenges concerning limits on cross-examination and excluded witness testimony for plain error and found none.

Holdings

1. Lambert was not in custody during the police interview because, considering the totality of the circumstances, a reasonable person in his position would have felt free to terminate the interview and leave; therefore, Miranda warnings were not required.
2. Lambert’s statements were voluntary because, under the totality of the circumstances, coercive governmental conduct did not overbear his free will.
3. The trial court did not violate Lambert’s confrontation rights by asking counsel to finish cross-examining M.M.’s mother within fifteen minutes because the court imposed a reasonable limit after extensive cross-examination and did not prevent counsel from exposing facts bearing on the witness’s reliability.
4. The trial court erred in ruling that the deed-related statement was inadmissible solely because it had not first been put to M.M.’s mother for impeachment, but neither that error nor the exclusion of the “living hell” statement constituted plain error because defendant could not show prejudice.

Questions Presented

1. Whether Lambert was in custody for Miranda purposes during his interview with detectives and therefore entitled to Miranda warnings.
2. Whether Lambert’s statements to the detectives were involuntary because police used deceptive and psychologically coercive interrogation tactics.
3. Whether the trial court violated Lambert’s confrontation and due-process rights by reasonably limiting cross-examination of M.M.’s mother.
4. Whether the trial court committed plain error by excluding testimony about statements allegedly made by M.M.’s mother showing bias or animus toward Lambert.

Disposition

affirmed