State v. Brunson
1995 Conn. App. LEXIS 19, 36 Conn. App. 576, 651 A.2d 1335 (1995)
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Rule of Law:
A suspect's voluntary and spontaneous statements made while in custody are admissible as evidence if they are not the result of police interrogation, even if made immediately after receiving Miranda warnings.
Facts:
- On November 19, 1991, Shawn Williams was shot in the chest in New Haven.
- Williams told Detective Leroy Dease that he was shot by someone he knew as 'Fat Harry,' with whom he had a previous fight in jail.
- Detective Dease presented Williams with a photo array, from which Williams identified Harry Brunson as the shooter.
- After police went to his home with a warrant, Brunson, accompanied by his parents, voluntarily presented himself at the New Haven police station.
- In a private room, Detective Dease advised Brunson of the charges and read him his Miranda rights.
- Immediately after indicating he understood his rights, and without any intervening questions from the detective, Brunson stated that he did not shoot Williams but had been present at the scene.
Procedural Posture:
- Harry Brunson was charged with assault in the first degree and carrying a pistol without a permit.
- Prior to trial, Brunson filed a motion to suppress statements he made to police, arguing they were obtained in violation of his Miranda rights.
- The trial court denied the motion to suppress, finding the statements were spontaneous and not the result of interrogation.
- Following a jury trial, Brunson was convicted on both charges.
- Brunson, as the appellant, appealed the judgment of conviction to the Connecticut Appellate Court, challenging the denial of his suppression motion and the sufficiency of the evidence for the pistol charge.
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Issue:
Does the Fifth Amendment require the suppression of a custodial suspect's statements when they are made voluntarily and spontaneously immediately after receiving Miranda warnings, but not in response to any police interrogation?
Opinions:
Majority - Foti, J.
No. The Fifth Amendment does not require suppression because Miranda protections are triggered only when a suspect is subject to both custody and interrogation. While Brunson was in custody, his statements were spontaneous and not made in response to any questioning or actions by the police that were reasonably likely to elicit an incriminating response. The court reasoned that a statement given freely and voluntarily, without any compelling influence, is admissible. The burden is on the defendant to demonstrate that an interrogation occurred, and here, the record supports the trial court's finding that the statements were spontaneous, as they were made immediately after Brunson acknowledged understanding his rights, leaving no time for the detective to ask a question.
Analysis:
This case reinforces the critical distinction between custody and interrogation under the Miranda doctrine. It clarifies that the protections of Miranda are not triggered by the custodial environment alone, but by the coercive pressure of police questioning within that environment. The decision affirms that a suspect's own unprompted statements are not protected, establishing a clear precedent that the government can use voluntary, spontaneous utterances against a defendant. This places a significant burden on the defendant to prove that their statement was the product of interrogation, rather than simply a voluntary act.
