State of West Virginia v. Asaveon Coleman

Summary

The Supreme Court of Appeals of West Virginia affirmed Asaveon Coleman's convictions and aggregate sentence arising from the kidnapping, robbery, shooting, and related offenses involving Tyler O’Neil. The court held that West Virginia’s juvenile prompt-presentment statute did not apply to Coleman’s interrogation by Virginia officers and that Coleman knowingly, intelligently, and voluntarily waived his Miranda rights. A dissent would have set the case for oral argument and issued a formal opinion.

Holdings

1. West Virginia Code § 49-4-705 did not apply to Coleman's confession because he was arrested in Virginia on a Virginia warrant, West Virginia officers were not involved in his arrest or apprehension, the Virginia detective acted independently while questioning him in Virginia, and Coleman failed to establish a working arrangement that would make the West Virginia prompt-presentment requirement applicable.
2. The circuit court did not clearly err in finding that Coleman voluntarily, knowingly, and intelligently waived his Miranda rights; his confession was therefore properly admitted.

Questions Presented

1. Whether West Virginia's juvenile prompt-presentment statute, West Virginia Code § 49-4-705(c), applied to Coleman's interrogation and required suppression of his confession obtained by Virginia police.
2. Whether Coleman knowingly, intelligently, and voluntarily waived his Miranda rights under the totality of the circumstances.

Disposition

affirmed