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Berghuis v. Thompkins, 560 U.S. 370, 130 S.Ct. 2250, 176 L.Ed.2d 1098, 78 USLW 4479, 10 Cal. Daily Op. Serv. 6731, 2010 Daily Journal D.A.R. 8047, 22 Fla. L. Weekly Fed. S 375

Facts

Van Chester Thompkins was convicted of first-degree murder after a shooting incident in Michigan. During a three-hour police interrogation, Thompkins remained largely silent and did not explicitly invoke his right to remain silent or request an attorney. Near the end of the interrogation, he answered 'yes' to a question about praying for forgiveness for the shooting. His defense at trial was that another individual was the shooter, but the prosecution relied on his statements made during the interrogation as evidence of his guilt.

Van Chester Thompkins was convicted of first-degree murder after a shooting incident in Michigan. During a three-hour police interrogation, Thompkins remained largely silent and did not explicitly invoke his right to remain silent or request an attorney.

Issue

Did Thompkins invoke his right to remain silent during the police interrogation, and did he receive ineffective assistance of counsel regarding the failure to request a limiting instruction about an accomplice's acquittal?

Did Thompkins invoke his right to remain silent during the police interrogation, and did he receive ineffective assistance of counsel regarding the failure to request a limiting instruction about an accomplice's acquittal?

Rule

A suspect's right to remain silent must be invoked unambiguously, and a waiver of that right can be implied from the suspect's conduct if the police have provided the necessary Miranda warnings.

A suspect's right to remain silent must be invoked unambiguously, and a waiver of that right can be implied from the suspect's conduct if the police have provided the necessary Miranda warnings.

Analysis

The Court determined that Thompkins did not invoke his right to remain silent because he did not make any unambiguous statements to that effect during the interrogation. His silence was not sufficient to invoke the right, and his later affirmative response to a question indicated a waiver of that right. Additionally, the Court found that even if his counsel's performance was deficient for not requesting a limiting instruction, Thompkins could not demonstrate that this failure prejudiced his case given the overwhelming evidence against him.

The Court determined that Thompkins did not invoke his right to remain silent because he did not make any unambiguous statements to that effect during the interrogation.

Conclusion

The Supreme Court affirmed the lower court's decision, concluding that Thompkins did not invoke his right to remain silent and that he was not denied effective assistance of counsel.

The Supreme Court affirmed the lower court's decision, concluding that Thompkins did not invoke his right to remain silent and that he was not denied effective assistance of counsel.

Who won?

The State of Michigan prevailed in the case, as the Supreme Court upheld the conviction and found that Thompkins did not invoke his right to remain silent.

The State of Michigan prevailed in the case, as the Supreme Court upheld the conviction and found that Thompkins did not invoke his right to remain silent.

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