California v. MoralesAnnotate this Case
Defendant-appellant Joel Morales was tried by jury and found guilty of second degree murder. The jury found true the allegation that he personally used a deadly and dangerous weapon. Defendant was sentenced to fifteen years to life in prison with the one-year enhancement. On appeal, defendant argued a police station interview turned custodial when officers pre-Miranda repeatedly accused defendant of lying and being deceitful, after informing defendant he failed a polygraph test. Defendant further contended the officers' subsequent midstream Miranda advisement was ineffective because his statements pre-Miranda were coerced, and thus all of his post-Miranda statements made during the same interview also should have been excluded. Concluding independently from the totality of the circumstances that after defendant took and (allegedly) failed the polygraph test, the Court of Appeal concluded a reasonable person in defendant's position would surmise that he or she was not free to leave the station. Furthermore, the Court concluded there was no substantial evidence to support the finding defendant's statements at the police station post-Miranda were uncoerced or were otherwise the product of his own free will. In light of its conclusion that the police subjected defendant to custodial interrogation in violation of Miranda when they questioned him for several hours at the police station, the Court also independently concluded the courthouse statements defendant made to the police four days later should have been suppressed as the product of such violation, as the record showed defendant was not given an additional Miranda advisement before questioning resumed. Lastly, the Court concluded the error in failing to exclude defendant's stationhouse and courthouse statements was not harmless beyond a reasonable doubt. Defendant's conviction was reversed and the case remanded back to the trial court with directions to vacate its order denying defendant's motion to suppress and for further proceedings.