Miranda Warnings when Individual Already Charged with Crime
Commonwealth v. Rawls, 2020 WL 119659 (Pa. Super.) (unreported), allocatur granted Aug. 25, 2020, appeal docket 49 MAP 2020
The Pennsylvania Supreme Court will consider whether law enforcement must do more than provide Miranda warnings to satisfy the right to counsel if law enforcement deliberately withheld that the detained individual has already been charged with a crime.
Superior Court summarized the relevant facts as follows:
On October 31, 2016, two victims, Kristine Kibler and Shane Wright, were shot and killed in their residence on Poplar Street in Williamsport, Pennsylvania. On November 10, 2016, law enforcement authorities filed a criminal complaint against Appellant, charging him with two counts of criminal homicide and other, related crimes arising from the aforementioned incident. The next day, Appellant voluntarily reported to the Williamsport Police Department after learning of media reports linking him to the Poplar Street homicides. N.T. Pre-Trial Hearing, 4/26/18, at 14. At the time Appellant reported to the Williamsport Police Department, he was unaware that he was criminally charged. Id. The Williamsport police arrested Appellant upon arrival. Id. at 13-14. The police then took Appellant to an interview room, read him his Miranda rights, and asked that he sign a waiver form, which he did. Id. at 15. After five and one-half hours of questioning, Appellant gave a statement to police admitting his involvement with the incident at Poplar Street. Id. at 36.
Slip op. at 1-2 (footnote omitted). Rawls was charged with numerous murder and robbery offenses. Rawls filed a motion to suppress his statement to police on the basis that his statement was obtained in violation of his Fifth, Sixth, and Fourteenth Amendment rights. The trial court denied Rawls’ motion to suppress. Following jury and bench trials, Rawls was convicted of first-degree murder, second-degree murder, robbery, criminal conspiracy to commit robbery, criminal attempt to commit robbery, possession of an instrument of a crime, persons not to possess firearms, and firearms not to be carried without a license. The trial court sentenced Rawls to consecutive life sentences for his first and second-degree murder convictions. Rawls appealed, arguing, among other issues, that the statements that he gave at the police station should be suppressed as they were obtained by the police in violation of his Sixth Amendment right to counsel.
Superior Court affirmed Rawls sentence on the basis of the trial court’s opinions, adopting the trial court’s opinions as its own. In particular, Superior Court agreed that the trial court did not err in admitting Rawls’ statement to police because Rawls executed a valid waiver of his Miranda rights and in turn, waived his Sixth Amendment right to counsel, reasoning that:
Herein, Appellant’s chief complaint is that, because the police failed to specifically inform him that he was criminally charged with the Poplar Street homicides, his Miranda waiver was invalid, i.e., it was made unknowingly and unintelligently. We disagree. At the suppression hearing, the Commonwealth demonstrated that, at the time Appellant entered the Williamsport Police Department, he knew that law enforcement was “looking for him” because “his picture [was] in the media in an attempt to identify him in relationship to the homicide on Poplar Street.” N.T. Pre-Trial Hearing, 4/26/18, at 14. The Williamsport police then advised Appellant that there was an arrest warrant for him, took him into custody, and read him his Miranda rights. Id. at 13. Before Appellant waived his Miranda rights and before police commenced any questioning, police also specifically informed Appellant that the arrest warrant was issued in conjunction with a police investigation of a criminal homicide. Id. at 33. Accordingly, we agree with the trial court’s determination that the mere fact that the police did not inform Appellant that he was criminally charged did not render his subsequent Miranda waiver unknowing or unintelligent. See Riddick v. Edmiston, 894 F.2d 586, 591 (3d. Cir. 1990) (holding that the defendant executed a valid waiver of his Miranda rights, and in turn, his Sixth Amendment right to counsel, even though law enforcement failed to specifically advise the defendant that he had been indicted on a murder charge); See Commonwealth v. Carr, 580 A.2d 1362, 1365-1366 (Pa. Super. 1990) (explaining that a suspect “need not have knowledge of the ‘technicalities’ of the criminal offense involved” to execute a valid waiver of his Miranda rights, “rather, it is necessary only that he be aware of the ‘transaction’ involved.”). Thus, while Appellant’s Sixth Amendment right to counsel attached upon the filing of the criminal complaint, the trial court correctly found a valid waiver of that right after Appellant received Miranda warnings and executed a waiver form.
Slip op. at 6 n.12.
The Pennsylvania Supreme Court granted allocatur to consider the following issues:
Whether police, to protect a person’s sixth amendment rights, must do more than administer Miranda warnings when the person is subject to police custodial interrogation and police deliberately fail to disclose that criminal charges have already been filed?