State v. Scales
518 N.W.2d 587, 1994 Minn. LEXIS 500, 1994 WL 315702 (1994)
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Rule of Law:
Under the Minnesota Supreme Court's supervisory power to ensure the fair administration of justice, all custodial interrogations must be electronically recorded when feasible. Failure to comply with this recording requirement will result in the suppression of any statements made during the interrogation if the violation is deemed substantial by the trial court.
Facts:
- Michael Jerome Scales lived with his girlfriend and her mother, Otha Brown.
- At approximately 1:00 a.m. on October 4, 1992, Scales told Otha Brown he was sick and asked her to drive him to the hospital.
- Scales returned to the house minutes later, stating Brown had forgotten her purse, and he took it along with his two-year-old son.
- Brown did not return home, and her body was discovered around 7:00 a.m. in an alley, having been stabbed 26 times.
- During the early morning hours, Scales was at a crack house using Brown's van and distributing her checks and credit cards.
- Scales made two unsuccessful attempts to use Brown's bank card shortly after the estimated time of her death.
- Scales told another individual that he had killed someone for money.
- Police discovered Brown's blood on Scales's clothes, shoes, and wallet, and found a bloody knife consistent with Brown's blood that matched a set from her kitchen.
Procedural Posture:
- Michael Jerome Scales was taken to the police station and interrogated for approximately three hours, but only the final formal question-and-answer portion was recorded.
- At a Rasmussen hearing, Scales moved to suppress his formal statement and other comments, arguing he had not received timely Miranda warnings and that the interrogation was not recorded.
- The Hennepin County District Court (trial court) denied the motion to suppress.
- Following a trial, a jury in the Hennepin County District Court convicted Scales of two counts of first-degree murder and one count of second-degree intentional murder.
- Scales was sentenced to life in prison.
- Scales appealed his conviction to the Minnesota Supreme Court, which is the state's highest court.
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Issue:
Does the failure of law enforcement to electronically record a custodial interrogation, when feasible, require suppression of any statements made by the suspect during that interrogation?
Opinions:
Majority - Wahl, Justice
Yes. In the exercise of its supervisory power, the court holds that all custodial interrogations must be electronically recorded where feasible to ensure the fair administration of justice. The court mandates this rule, prospectively, as a necessary safeguard for an accused's right to counsel, right against self-incrimination, and right to a fair trial. A recording provides an accurate record that protects defendants from false testimony and police from meritless claims, while also discouraging coercive police tactics. If law enforcement fails to comply with this recording requirement, any resulting statements may be suppressed if the trial court determines the violation was 'substantial'. Although the police failed to record the interrogation in this case, the error was harmless due to the overwhelming independent evidence of Scales's guilt, so his conviction is affirmed.
Concurring-in-part-and-dissenting-in-part - Tomljanovich, Justice
No. While recording interrogations is desirable, it is not essential for a fair trial and should not be mandated through an exclusionary rule, which is a drastic remedy. This decision departs from the rule in the vast majority of other jurisdictions. The court should not impose such a significant policy change under its supervisory powers without a full hearing and adequate notice to law enforcement. The matter should instead be referred to the Supreme Court Advisory Committee on Rules of Criminal Procedure for further study and consideration.
Analysis:
This landmark decision makes Minnesota one of the first states to mandate the electronic recording of custodial interrogations. By using its supervisory power rather than basing the rule on the state constitution, the court created a prophylactic rule designed to improve the administration of justice and protect defendants' rights. The decision places a significant burden on law enforcement to adopt recording technology and procedures to avoid the suppression of critical evidence. The inclusion of a 'substantial violation' test provides trial courts with discretion, preventing automatic suppression for minor, good-faith failures to record and focusing the remedy on willful or prejudicial violations.
