The Ninth Circuit Federal Court of Appeal recently overturned a California state court conviction based on a finding of clear Miranda error. (See Garcia v. Long, No. 13-57071.) The accused person answered a simple “no” when officers read him his Miranda rights and asked if he wanted to talk. Instead of stopping the interrogation, the officers asked follow-up questions to clarify the person’s reasons for invoking his Miranda rights. The officers asked if he was just uncertain about the charges against him. The accused person took the bait. He eventually agreed to talk to the officers if they explained the charges. After hearing the charges, he gave a detailed and lengthy confession. He objected at trial that the confession violated his Miranda rights. The trial court overruled the objection and allowed the prosecutor to present the confession to the jury.
Clear Error in Applying Miranda and Determining the Facts
The Ninth Circuit had to meet a high bar in overturning the California state court conviction in Garcia. In 1996, the United States Congress passed a law (i.e. Anti-terrorism and Effective Death Penalty Act) that restricted federal judicial review of state court convictions. The law prohibited federal courts from overturning state court convictions unless the state court was not just wrong, but clearly wrong. The Ninth Circuit in Garcia had to find that the California District Court of Appeal (DCA) (a) clearly erred in applying the Miranda rule as established by the United States Supreme Court or (b) clearly erred in deciding what the facts were. The Ninth Circuit found that the DCA committed clear error in both respects. Continue reading →