STATE v. WILFREDO RAMOS, SC 19188
Judicial District of Waterbury
Criminal; Police Interrogations; Whether Confession Given in Response to Improper “Question First” Interrogation Tactic; Whether Confession Illegally Obtained as a Result of Police Coercion. In 2011, Waterbury police detectives questioned the defendant at the police station regarding the stabbing death of Linda Graveline. Noticing that the defendant was bleeding, the detectives asked him what had happened and whether he was okay. The defendant responded that he had stabbed himself during a struggle. At that point, the detectives informed the defendant of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966), after which he confessed to stabbing Graveline. The defendant was subsequently charged with murder. Prior to trial, the defendant moved to suppress his confession, arguing that he did not knowingly and voluntarily waive his right to remain silent under Miranda. The trial court denied the motion, finding that the defendant had not been subjected to a police interrogation pursuant to Miranda because at the time that the detectives interviewed him, they did not know whether he was a suspect or a victim and their questions were not intended to elicit an incriminating response. The court further determined that even if the defendant had been subjected to a police interrogation, his confession was given voluntarily because he freely acknowledged that he was familiar with his rights in light of his prior involvement with the criminal justice system. The court added that the interview process was not confrontational and that the defendant had fully cooperated with the detectives and had freely provided his version of the incident. The defendant was subsequently convicted of murder. In this appeal, the defendant argues that his confession should have been suppressed because it was involuntarily given in response to an improper “question first” interrogation tactic in violation of Missouri v. Seibert, 542 U.S. 600 (2004). The defendant maintains that the detectives did not provide him with his Miranda warnings until after their initial interrogation elicited his incriminating statement that he had stabbed himself during a struggle. He claims that, in light of the fact that he had already provided an incriminating statement, the subsequent Miranda warnings were insufficient to give him the reasonable belief that he had the genuine right not to speak to the police. The defendant’s final claim is that the confession was illegally obtained as a result of police coercion in that he was interrogated continuously for five hours without food, water, or rest and that he was physically weakened by his knife wounds and by an underlying medical condition.