Commonwealth v. Haynes

Rule of Law:

A confession made during an illegal custodial detention is not automatically suppressed as fruit of the poisonous tree if the taint of the initial illegality is purged by intervening circumstances, such as confronting the suspect with incriminating evidence that prompts the confession.

Facts:

• Eddilee Sims, the 53-year-old mother of Angelo P. Haynes' friend, was found dead from stabbing and strangulation.
• Detectives Bauer and McGuire of the City of Pittsburgh went to the neighboring municipality of Wilkinsburg to find Haynes at his girlfriend's home.
• The detectives were aware of a three-year-old outstanding bench warrant for Haynes but were unsure of its status.
• The detectives told Haynes they were investigating the Sims murder but asked him to accompany them to the police station to 'clear up' the outstanding bench warrant.
• Haynes consented to go with the officers believing the purpose of the trip was to resolve the warrant.
• Immediately upon arrival at the Pittsburgh police station, Haynes was placed in an interrogation room, read his Miranda rights, and questioned about the Sims homicide.
• After approximately one hour and fifteen minutes of interrogation, police told Haynes his fingerprints and palm prints matched those found on the victim's door, which had been forced open.
• Upon being confronted with this evidence, Haynes stated that he broke into the apartment but claimed another person, Dan Smith, had killed Ms. Sims.

Procedural Posture:

• Angelo P. Haynes was tried before a jury in the court of first instance.
• The jury found Haynes guilty of First Degree Murder.
• The trial court imposed a sentence of life imprisonment.
• Haynes filed post-trial motions, including a motion to suppress his statements, which the trial court denied.
• Haynes, the appellant, appealed his conviction and the denial of his motions to the Superior Court of Pennsylvania, an intermediate appellate court.