Customized Miranda Warnings Given to Sophisticated Defendant Conveyed the “Essential Message”

Written by Lindsay E. Raber, Esq.

In a criminal law matter, the Appellate Court of Connecticut found that a trial court properly denied a defendant’s motion to suppress evidence, because an officer’s recitation of the Miranda warnings adequately apprised him of his rights.

The Case

This case arose from an incident that occurred on September 15, 2007, in Stamford. The defendant repeatedly struck a victim in the head using an aluminum baseball bat. The victim suffered life-threatening injuries but survived. The defendant fled to North Carolina, where he was apprehended and returned to Connecticut with two Stamford police officers. During this trip, the defendant made incriminating statements he later sought to suppress.

At the suppression hearing, the officer testified that he gave the defendant the following warnings during the trip:

[H]e has the right to remain silent. Anything he says can and will be used against him in a court of law. He has the right to an attorney. If he cannot afford one, the court will appoint him one. He has the right to stop answering questions at any time. He has the right to invoke his privilege to an attorney at any time. He has the right to not answer specific questions, if he wants to pick and choose the questions he wants to answer.

The officer explained that he prefers to go “above and beyond” the Miranda requirements with added explanations. He asked the defendant whether he understood the warnings, to which the defendant replied, “I know them, I know them, I know them.” The officer testified that at this time, the defendant waived his rights and wished to speak with them.

The Miranda Warnings

The court denied the motion to suppress, noting that the defendant, who had numerous previous arrests, “is very sophisticated, very intelligent and seems to understand a great deal [about] the legal process.” It found that the defendant was “a seasoned individual who understands what Miranda rights are about.” After a jury trial, the defendant was convicted of assault in the first degree in violation of Connecticut General Statutes § 53a-59(a)(1).  On appeal, he claimed the officer’s recitation of Miranda was inadequate, thus the trial court erred in denying his motion. He did not contest how the trial court characterized him.

In the landmark ruling of Miranda v. Arizona, the U.S. Supreme Court recognized the indispensability of counsel at the time of custodial interrogation. The Miranda warnings make sure that a defendant understands his or her constitutional rights, and if police engage the defendant in questioning without reciting these rights, the defendant’s statements may be suppressed. Thus, when a reviewing court considers the adequacy of Miranda warnings, it simply asks “whether the warnings reasonably conve[y] to [a suspect] his rights as required by Miranda.”

The Court’s Ruling

In this case, the Appellate Court ruled that the officer’s warnings were adequate because they “communicated the same essential message” as required under Miranda. The Court highlighted the defendant’s familiarity with these rights, as evidenced by the trial court’s characterization and his repeated acknowledgement to the officer. “The essential purpose of Miranda warnings is to provide a criminal suspect with the informed choice either to exercise his [f]ifth and [s]ixth [a]mendment rights or to waive them.” Here, the Court stated that aim was accomplished. Therefore, the trial court did not err in denying the motion to suppress evidence.

Should you have any questions regarding criminal defense, please do not hesitate to contact Attorney Joseph C. Maya in the firm’s Westport office in Fairfield County at 203-221-3100 or at JMaya@Mayalaw.com.