State v. Ruiz-Piza

Summarized by:

  • Court: Oregon Court of Appeals
  • Area(s) of Law: Criminal Procedure
  • Date Filed: 05-30-2014
  • Case #: A155032
  • Judge(s)/Court Below: Egan, J. for the court; Armstrong, P.J.; & De Muniz, S.J.
  • Full Text Opinion

A confession induced through fear is a strong indicator of involuntariness when considered as part of the totality of the circumstances during a suppression hearing.

Defendant was indicted for allegedly shaking his infant daughter, and moved to suppress statements he made to police during an interview. The trial court granted defendant’s motion to suppress, leading the state to make this interlocutory appeal. The state argued that the trial court erred in determining that defendant’s statements to police were made involuntarily. The Court held that, under the totality of the circumstances, defendant’s statements were not made voluntarily; when officers drew a distinction between two criminal alternatives as the sole paths defendant could follow, they induced defendant to confess. Furthermore, officers implied that defendant’s confession was the only way to help his daughter recover, which also amounted to inducement through fear. Affirmed.

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