State v. Sawyer
2005 Tenn. LEXIS 115, 156 S.W.3d 531, 2005 WL 434788 (2005)
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Rule of Law:
An officer's act of reading a detailed affidavit of complaint to a suspect in custody constitutes the functional equivalent of interrogation when the totality of the circumstances would lead a reasonable person to believe they are being questioned.
Facts:
- Detective Kevin Clark and another officer obtained an arrest warrant for Charles Sawyer for aggravated sexual battery, supported by an affidavit detailing the allegations.
- The officers went to Sawyer's residence, where Detective Clark arrested him and told him they 'would go down to the jail, and [they] would discuss what was going on.'
- The officers handcuffed Sawyer, placed him in a patrol car, and transported him directly to the Marshall County jail.
- Upon arrival approximately thirty minutes after the arrest, officers escorted Sawyer to Detective Clark’s office for an intended interview, removed his handcuffs, and seated him across a desk from the detective.
- Before advising Sawyer of his Fifth Amendment rights, Detective Clark read aloud both the arrest warrant and the affidavit of complaint, which specified that Sawyer allegedly rubbed the leg and vaginal area of a 12-year-old victim.
- Immediately after hearing the specific allegations in the affidavit, Sawyer made an incriminating statement, saying, 'I admit to rubbing her leg, but I didn’t do the other.'
- Only after Sawyer made this statement did Detective Clark advise him of his Miranda rights, at which point Sawyer requested counsel.
Procedural Posture:
- Charles Sawyer filed a motion in the trial court to suppress his oral statement to police.
- The trial court granted the motion to suppress, finding the officer's actions were the functional equivalent of interrogation.
- The State of Tennessee, as appellant, filed an interlocutory appeal to the Court of Criminal Appeals.
- The Court of Criminal Appeals, an intermediate appellate court, affirmed the trial court's judgment suppressing the statement.
- The Supreme Court of Tennessee, the state's highest court, granted the State's petition for review.
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Issue:
Does an officer's act of reading a detailed affidavit of complaint to a suspect in custody, before providing Miranda warnings, constitute the functional equivalent of interrogation in violation of the Fifth Amendment?
Opinions:
Majority - Justice Holder
Yes. An officer reading a detailed affidavit of complaint to a suspect under these circumstances is the functional equivalent of an interrogation. Under Rhode Island v. Innis, an interrogation includes not only express questioning but also any words or actions by police that they should know are reasonably likely to elicit an incriminating response. The court distinguished this case from those where officers merely read the charge on the warrant, which is generally permissible. Here, the totality of the circumstances—including the officer telling Sawyer they would 'discuss' the matter, taking him directly to an interview room, and reading the specific, detailed allegations from the affidavit—created an environment where Sawyer could reasonably believe the interrogation had begun. These actions were likely to evoke an incriminating response and therefore required prior Miranda warnings.
Analysis:
This decision clarifies the line between merely informing a suspect of the charges and engaging in the 'functional equivalent of interrogation' under the Innis standard. It establishes that the context and specific content of police communication are critical. By focusing on the totality of the circumstances, the court signals that police cannot use the pretense of providing information to create a coercive environment designed to elicit a confession before giving Miranda warnings. This ruling will likely cause law enforcement agencies to be more cautious about the information they provide to suspects in custody before Miranda rights have been waived, particularly in formal interview settings.
