State v. MatsumotoAnnotate this Case
The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that the trial court erred in determining that Defendant's confession was voluntarily made despite an interrogating officer informing him, untruthfully, that he did not pass a polygraph test, holding the deliberate falsehood regarding the polygraph results impermissibly tainted Defendant's confession.
The trial court admitted Defendant's confession into evidence over defense objection. The court further ruled that during Defendant's trial testimony, when discussing the circumstances of his confession, could not mention the words "polygraph" or "test" or that the interrogating officer gave him inaccurate test results before his confession was elicited. The Supreme Court vacated the conviction, holding (1) the admission of Defendant's confession was not harmless error; (2) the exclusion of evidence of the circumstances surrounding the eliciting of Defendant's confession severely compromised Defendant's constitutional right to a fair trial and to present a complete defense; and (3) the court's jury instruction that defined an element of the charged offense contained a misstatement of law and was ambiguous and incomplete.