The Court of Appeals recently reviewed a Michigan defendant’s appeal of his criminal sexual conduct conviction. Amongst several issues, the defendant argued that his statements were involuntary because he was impaired due to prescription medication. The case stems from an interaction between the defendant and the victim during a marijuana transaction. The facts indicate that the defendant and complainant drove to the defendant’s friend’s apartment to purchase marijuana. The victim contends that the defendant sexually assaulted her in the car twice. However, the defendant asserts that although the complainant refused at first, she allowed him to touch her and have consensual intercourse.
Following the incident, the complainant sought treatment at a local hospital, and her sexual assault kit sat untested for over ten years. In 2018 detectives discovered that the defendant’s DNA was associated with four other sexual assaults. After a bench trial, the defendant was convicted. Amongst several issues, he argued that the judge erred by denying his motion to suppress his statement to detectives.
State and federal law provide protections against self-incrimination. Relatedly, involuntary statements to law enforcement are inadmissible. Courts will look to the totality of the circumstances to determine whether a statement was freely given. In this analysis, some common factors are the accused’s age, nature of questioning, length of detention, presence of an attorney, and the accused’s impairment and health.
In this case, the detectives interviewed the defendant the morning he was arrested. Detectives did not record the interview because of an equipment malfunction. The defendant asserts that before the interview, he took prescription pain, seizure, and diabetes medications. Further, he explained that he was on dialysis. The detectives read the defendant his Miranda rights; however, the defendant testified that he did not have his glasses, so he could not read the rights. He argued that not all of the initials on the form were in his handwriting. The detectives contended that the defendant appeared to communicate freely and effectively, and he never spoke up about the need for a break.
Michigan courts have found that pain medication is not relevant or significant if the defendant remains alert, articulate, and responsive during interviewing or interrogation. Ultimately, the court found that the defendant’s statements appeared to be voluntary under the totality of the circumstances. Thus, the trial court did not err in denying his motion to suppress and finding that the statements were admissible.
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