Pennsylvania v. Rawls (majority)
Annotate this CaseThis appeal centered on whether law enforcement agents violated the Sixth Amendment to the United States Constitution when, although issuing Miranda warnings to an arrestee during an interrogation, they failed to specifically apprise him that criminal charges already had been filed against him. In October 2016, Appellant Jordan Rawls and Joseph Coleman perpetrated a home-invasion robbery, during which Kristine Kibler and her son, Shane Wright, were shot and killed. An accomplice, Casey Wilson, served as getaway driver. While shackled, Appellant was interrogated by agents for a period of five-and-one- half hours. At the outset, the lead investigator read Appellant his Miranda rights. He was also specifically admonished that: he was under arrest; he wasn’t free to leave; the agents were investigating the criminal homicides that had appeared in the news; and they had probable cause to obtain a warrant for his arrest. The agents, however, did not specifically advise Appellant that charges already had been lodged against him. During the interrogation, Appellant initially denied knowing Coleman or Wilson and pervasively lied about his whereabouts before, at, and after the time of the home invasion. The agents repeatedly confronted him with contrary evidence. Ultimately, Appellant admitted that he was present at the crime scene when the robbery and homicides were committed, but he professed to having been unarmed, claiming to have served “basically like . . . the lookout.” With regard to the charges filed, Appellant argued that without such information, the waiver of his rights could not be deemed to have been knowing and intelligent. After conducting a hearing, the suppression court found that Appellant had rendered a valid waiver of his right to counsel after receiving appropriate Miranda warnings; the court found nothing to indicate that he was incapable of understanding the rights explained to him and no evidence that the agents threatened, tricked, or cajoled him. Finding no error in the suppression court's judgment, the Pennsylvania Supreme Court affirmed: there was no per se rule invalidating such a waiver merely because an arrestee was not advised that charges had been filed.
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