STATE OF FLORIDA, APPELLANT,
v.
JARI GOODWIN, APPELLEE
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The State appealed a trial court's suppression of post-Miranda statements made by Jari Goodwin during a police interview. The appellate court reversed, holding that an uncoerced pre-Miranda statement does not taint a subsequent post-Miranda statement when proper Miranda warnings are given before the second statement.
The court held that voluntary, uncoerced pre-Miranda statements do not taint subsequent post-Miranda statements. A suspect who responds to unwarned yet uncoercive questioning is not disabled from waiving his rights and confessing after receiving proper Miranda warnings, and the subsequent warned statement is admissible.
[1] A suspect who has once responded to unwarned yet non-coercive questioning is not disabled from waiving his rights and confessing after receiving the requisite Miranda war…
[2] An unwarned, voluntary statement does not trigger the "fruit of the poisonous tree" doctrine if the defendant is subsequently given proper Miranda warnings and knowingly…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a suspect who has once responded to unwarned yet un-coercive questioning is not thereby disabled from waiving his rights and confessing after he has been given the requisite Miranda warnings”
Establishes the core legal principle from Oregon v. Elstad that unwarned voluntary statements do not prevent subsequent Miranda-compliant confessions
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceGoodwin was arrested and transported to the sheriff's substation. A detective had a casual hallway conversation with Goodwin without first advising hi…
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KELLY, Judge.
The State appeals the trial court’s suppression of post-Miranda
statements made by Jari Goodwin during an interview conducted by law enforcement at the sheriffs office. After a review of the record, we conclude that Goodwin’s statements were voluntary and therefore reverse.
Goodwin and two codefendants were charged with conspiracy to commit armed robbery and attempted armed robbery. After his arrest and transport to the sheriffs substation, Goodwin made incriminating statements to a detective during what the detective described as a “casual conversation” that occurred as he passed Goodwin in a hallway. Goodwin had not been advised of his Miranda rights at this point.
Goodwin was then moved to an interview room and questioned by a second detective. This detective was unaware of the statements Goodwin had made in the hallway. After introducing himself, the detective informed Goodwin of his Miranda rights. He then recorded a statement from Goodwin, in which Goodwin answered all of his questions. The detective testified that Goodwin was cooperative and never sought to invoke any of his rights.
Goodwin moved to suppress both his p;re-Miranda and post-Miranda statements. In granting Goodwin’s motion, the trial court found that Goodwin’s pre-Mi-randa statements tainted his post-Miranda statements and that the intervening Miranda warning could not eliminate that taint. We disagree.
In Oregon v. Elstad, 470 U.S. 298, 318, 105 S.Ct. 1285, 84 L.Ed.2d 222 (1985), the Supreme Court held that “a suspect who has once responded to unwarned yet un-coercive questioning is not thereby disabled from waiving his rights and confessing after he has been given the requisite Miranda warnings.” See also State v. Polanco, 658 So. 2d 1123 (Fla. 3d DCA 1995) (holding that an unwarned, voluntary statement does not trigger the “fruit of the poisonous tree” doctrine. If the defendant is subsequently given proper Miranda warnings and knowingly and voluntarily makes a warned statement, then the warned statement is admissible). Goodwin’s unwarned statements were not the result of any coercive measures, and Goodwin does not suggest that he did not receive proper Miranda warnings before making additional incriminating statements. Accordingly, the trial court erred in suppressing Goodwin’s post-Miranda statements.
Reversed.
BLUE, C.J., and CASANUEVA, J., Concur. . Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966)
- Oregon v. Elstad, 470 U.S. 298 (U.S. 1985)
- State v. Polanco, 658 So. 2d 1123 (Fla. 3d DCA 1995)