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Keywords

defendantattorneyappealhearingtrialinterrogation

defendantliabilitytrialwillinterrogationbeyond a reasonable doubt

Related Cases

State v. Deets, 187 Wis.2d 630, 523 N.W.2d 180

Facts

Roger Deets was charged with multiple counts of first-degree sexual assault of a child. Prior to the charges being filed, Detective Flood interrogated Deets, during which he expressed dissatisfaction with Deets's answers and suggested that if Deets did not cooperate, the district attorney would view the case differently. After an evidentiary hearing, the trial court found that these actions constituted coercive police conduct and suppressed Deets's statements. The State appealed this decision.

The trial court found evidence of improper and coercive police conduct in three particulars and suppressed statements that defendant, Roger Deets, made to a detective. The State concedes the accuracy of the trial court's factual determinations.

Issue

Did the detective's conduct during the interrogation constitute coercive behavior that rendered Deets's statements involuntary?

Rule

Involuntary statements are inadmissible under the Fifth Amendment, and coercive police activity is a necessary predicate to finding that a confession is not voluntary. The determination of voluntariness requires a balancing of the defendant's personal characteristics against any coercive police pressures.

As we said in State v. Pheil, 152 Wis.2d 523, 535, 449 N.W.2d 858, 863 (Ct.App.1989), 'The fourteenth amendment prohibits involuntary statements because of their inherent unreliability and the judicial system's unwillingness to tolerate illegal police behavior.'

Analysis

The Court of Appeals analyzed the trial court's findings and concluded that the detective's statements did not amount to coercive conduct. The court reasoned that expressing dissatisfaction with a defendant's responses and suggesting that cooperation would be beneficial did not constitute coercion. Additionally, the suggestion that the victims would suffer trauma if forced to testify was deemed a reasonable prediction rather than coercive.

Because the trial court's factual findings do not justify the conclusion that the police acted coercively, we reverse the order suppressing Deets's statements.

Conclusion

The Court of Appeals reversed the trial court's order suppressing Deets's statements, concluding that the detective's conduct did not constitute coercive behavior.

We conclude that in view of its three findings, it was unable to find beyond a reasonable doubt that Deets's inculpatory statements to the detective were voluntary.

Who won?

The State prevailed in the case because the Court of Appeals found that the trial court's suppression of Deets's statements was not justified by coercive police conduct.

The majority concludes as a matter of law that these three instances do not add up to coercive police activity. I disagree.

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