Bobby v. Dixon
November 7, 2011
Case #: 10-1540
Full Text Opinion: http://www.supremecourt.gov/opinions/11pdf/10-1540.pdf
Criminal Procedure: Antiterrrorism and Effective Death Penalty Act (AEDPA) provides that a state prisoner seeking a writ of habeas corpus from a federal court “must show that the state court’s ruling on the claim being presented in federal court was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.”Dixon and his accomplice murdered Chris Hammer to steal his vehicle. Dixon assumed the victim's identity, sold the vehicle and forged the victim's signature to cash a check from the vehicle sale proceeds. Dixon was arrested by police for forgery. He was not given his Miranda rights prior to interrogation. Dixon admitted to the forgery, but denied knowledge of Mr. Hammer's disappearance. Police then transported Dixon to the police station. Prior to further police questioning, Dixon stated to police he heard they found the body of Chris Hammer, and stated he talked to his attorney and wanted to tell them what happened. Dixon was given his Miranda rights at that time, and signed a waiver of those rights. Dixon then confessed to the murder. The murder confession was used to convict and sentence Dixon to death. Respondent was convicted of murder, which the Ohio State Supreme Court affirmed. Respondent appealed to the Sixth Circuit, which overturned the conviction.
The Supreme Court held that the sixth Circuit erred in overturning the conviction because 1) a Defendant who refuses to speak to the police without his lawyer while not in custody, can not anticipatorily invoke his Miranda rights for when he is later taken into custody; 2) The Court has refused to find that a defendant who confesses, after being falsely told that his codefendant has turned State’s evidence, does so involuntarily; 3) A deliberate question-first, warn-later strategy was not used in this case because there was no nexus between Dixon's unwarned admission to forgery, and his later, warned confession to murder. A nexus did not exist because the time between interrogations, the ability to talk with a lawyer in between interrogations, and the defendant learning of the police's finding of the body sufficiently changed circumstances to make Miranda warnings effective.
The Supreme Court reversed the judgment of the Sixth Circuit because the Ohio Supreme Court was justified in its reasoning affirming the murder conviction. The case was remanded to the Sixth Circuit.