Murray v. State
1993 Wyo. LEXIS 110, 855 P.2d 350, 1993 WL 216674 (1993)
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Rule of Law:
A law enforcement officer's violation of a state procedural rule requiring an arrestee to be informed of the charge does not render an otherwise valid arrest illegal or mandate the suppression of subsequent statements. Suppression is only appropriate if the defendant demonstrates prejudice or that officers intentionally and deliberately disregarded the rule in bad faith.
Facts:
- Donald Murray and the victim were friends and coworkers on an oil rig.
- On September 30, 1991, after finishing their shift and drinking, Murray and the victim argued at a bar.
- Murray left the bar and went to his home.
- Later that evening, the victim went to Murray's house to retrieve his work clothes from Murray's truck.
- Murray emerged from his house with a handgun and ordered the victim to leave his property.
- Murray fired several shots, including two near the victim's feet.
- As the victim turned to walk back to his car, Murray fired additional shots.
- One bullet ricocheted off a rock, struck the victim in the thigh, severed his femoral artery, and caused his death.
Procedural Posture:
- Donald Murray was arrested pursuant to a warrant and initially charged with second-degree murder.
- The prosecution later reduced the charge to involuntary manslaughter.
- Prior to trial, Murray filed a motion in the trial court to suppress statements he made after his arrest, arguing they were obtained in violation of W.R.Cr.P. 4(c)(3).
- The trial court denied the motion to suppress.
- Following a trial, a jury found Murray guilty of involuntary manslaughter.
- Murray (appellant) appealed his conviction to the Wyoming Supreme Court, challenging the denial of his suppression motion and the sufficiency of the evidence.
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Issue:
Does a law enforcement officer's failure to inform a defendant of the specific charge against him at the time of a valid arrest, in violation of a state rule of criminal procedure, render the arrest illegal and require the suppression of subsequent statements?
Opinions:
Majority - Macy, Chief Justice
No. A violation of a procedural rule during an arrest does not automatically render the arrest illegal or require the suppression of evidence. The court held that the arrest was legal because it was based on a valid warrant supported by probable cause. The officers' failure to comply with W.R.Cr.P. 4(c)(3) was a procedural violation, not a constitutional one. Adopting a test from cases concerning search warrants, the court reasoned that suppression is only warranted if the violation resulted in prejudice to the defendant or if there was evidence of an intentional and deliberate disregard of the rule by officers. Here, Murray was not prejudiced because he clearly knew he was being arrested for shooting the victim, and knowing the specific charge of second-degree murder would not have altered his decision to speak. Furthermore, the court found no evidence that the officers acted in bad faith or deliberately violated the rule to gain a tactical advantage.
Analysis:
This case clarifies the distinction between constitutional violations and procedural errors in criminal procedure, limiting the application of the exclusionary rule. It establishes that technical violations of rules of procedure do not automatically trigger suppression, a remedy typically reserved for more substantial infringements of rights. The decision sets a precedent requiring defendants to show actual prejudice or intentional police misconduct to have evidence excluded for such procedural errors. This raises the bar for defendants seeking to suppress evidence and gives law enforcement some leeway for non-prejudicial mistakes made during an otherwise lawful arrest.
