State v. Norgren

Rule of Law:

For a waiver of Miranda rights to be considered knowing and intelligent, the state must prove under the totality of the circumstances that the defendant possessed the requisite level of comprehension, focusing on the defendant's state of mind at the time of the waiver.

Facts:

• The defendant was on a medical leave of absence from university to address his mental health and was not taking his prescribed medication.
• The day before the incident, the defendant's family observed him becoming manic.
• On the morning of the incident, the defendant was rambling incoherently, broke a window with his hand causing it to bleed, removed all his clothing, and fled his home.
• Deputy Wheaton discovered the defendant in the woods, unconscious, naked, lying in a fetal position, and bleeding from his nose, hands, and feet.
• Wheaton handcuffed the defendant, who then regained consciousness.
• Immediately upon standing the defendant up, Wheaton read him his Miranda rights from a prepared card.
• The defendant responded "Yes" when asked if he understood his rights, but then made incriminating statements and told the deputy that "he was a sasquatch and he was from a family of sasquatches."

Procedural Posture:

• The defendant was charged with attempted murder and second-degree assault.
• Before trial, the defendant filed a motion in the trial court to suppress statements he made to the police.
• The trial court held a suppression hearing, where it heard testimony from the arresting officer and the defendant's family.
• The trial court denied the defendant's motion to suppress, finding that he had been properly given his Miranda rights and had validly waived them.
• Following a trial, the defendant was convicted.
• The defendant (as appellant) appealed the judgment of conviction to the Court of Appeals of Oregon, arguing the trial court erred in denying his motion to suppress.