Kalmakoff v. Alaska
Annotate this CaseA jury convicted Defendant Byron Kalmakoff of raping and murdering his cousin when he was fifteen years old. Troopers sent to investigate the murder conducted four interviews with Defendant. Before trial, Defendant moved to suppress statements he made in those interviews based on "Miranda" violations. The trial court suppressed a portion of the first interview and all of the second, but admitted the third and fourth interviews. The court of appeals affirmed Defendant's convictions, concluding that any error in admitting portions of the first interview was harmless and that the third and fourth interviews were "sufficiently insulated" from any Miranda violations that occurred during the first two interviews. The Supreme Court remanded the case to the trial court for additional fact findings and concluded that the Miranda violations from the first two interviews violated Defendant's right to remain silent. As such, the third and fourth interviews were tainted by violations in the first two interviews. The Court reversed Defendant's convictions and remanded the case for a new trial.
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