Miller v. State
770 N.E.2d 763 (2002)
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Rule of Law:
A defendant is deprived of the opportunity to present a defense when a trial court excludes expert testimony on the social psychology of police interrogation and false confessions, as this topic is generally outside the common knowledge of a jury and is critical for assessing the weight and credibility of a defendant's confession.
Facts:
- Anna Pennington, a 71-year-old apartment manager, was beaten, sexually assaulted, and strangled to death in her office.
- After hearing his name on a television news broadcast in connection with the murder, Ronnie G. Miller voluntarily went to the police station.
- During a lengthy interrogation, Detective Craig Converse falsely told Miller that witnesses had seen him outside the victim's office.
- Detective Converse presented Miller with a fabricated fingerprint card and computer printout, claiming Miller's fingerprints were found in the victim's office.
- Converse also showed Miller an erroneous police report stating the victim died of natural causes and suggested to Miller that her death could have been an accident.
- Following these tactics, Miller, who was later determined to be mentally retarded, made incriminating statements admitting he was in the office and that the victim fell after he pushed the door open.
- Miller described physical contact with the victim as an accident while trying to keep her from falling, but he denied sexually assaulting her.
Procedural Posture:
- Ronnie G. Miller was charged with murder and criminal deviate conduct in a state trial court.
- The State sought the death penalty, but the trial court dismissed the death penalty count after finding Miller to be mentally retarded.
- Miller filed a pre-trial motion to suppress his videotaped statement to police, arguing it was coerced.
- The trial court denied the motion to suppress.
- The State filed a motion in limine to exclude the testimony of the defense's expert on false confessions, Dr. Richard Ofshe.
- After a hearing, the trial court granted the State's motion, prohibiting Dr. Ofshe from testifying before the jury.
- A jury found Miller guilty of murder and criminal deviate conduct.
- The trial court sentenced Miller to consecutive prison terms of sixty-five years and twenty years.
- Miller appealed his conviction to the Indiana Supreme Court, arguing, among other things, that the trial court erred in excluding his expert witness.
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Issue:
Does a trial court commit reversible error by completely excluding expert testimony on the psychology of police interrogation techniques and false confessions, offered to help the jury assess the weight and credibility of a mentally retarded defendant's confession?
Opinions:
Majority - Dickson, J.
Yes, the trial court committed reversible error. A defendant is entitled to challenge the weight and credibility of a confession before the jury, even after a trial court has deemed it admissible. Expert testimony on the psychology of police interrogation and the phenomenon of false confessions, particularly concerning mentally retarded individuals, addresses issues beyond the common knowledge and experience of ordinary jurors and would aid their understanding. By excluding the expert's testimony in its entirety, the trial court deprived Miller of the opportunity to present a defense. This error was not harmless, given the State's heavy reliance on the confession during its case, thus requiring a new trial.
Concurring - Boehm, J.
Yes, the trial court erred. I concur with the majority's conclusion but write separately to note that the admissibility of Dr. Ofshe's testimony under Indiana Evidence Rule 702 was not specifically argued by the parties. Furthermore, jurisdictions are split on the admissibility of expert testimony regarding false confessions, highlighting the complexity of this evidentiary issue.
Analysis:
This decision establishes an important precedent in Indiana recognizing the value and admissibility of expert testimony on the coercive nature of police interrogations and the phenomenon of false confessions. It affirms that the psychological dynamics of an interrogation, especially with a vulnerable defendant, are not within the jury's common understanding. The ruling empowers defendants to meaningfully challenge the credibility of their own confessions at trial, moving beyond the simple admissibility question decided by the judge. This will likely encourage the use of such experts in future cases and require trial courts to allow testimony that explains these complex psychological processes, so long as the expert does not improperly opine on a specific witness's truthfulness.
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