People v. Harris, 57 N.Y.2d 935 (1982)
A defendant’s spontaneously volunteered statement, not the result of inducement, provocation, encouragement, or acquiescence, is admissible even after the right to counsel has attached.
Summary
Harris was arrested for fatally stabbing an inmate. At arraignment, with a Spanish interpreter present due to Harris’s limited English, he spontaneously confessed his guilt after the Town Justice spoke. The translator, believing Harris had a question about the Justice’s statement, allowed him to speak. The New York Court of Appeals affirmed the lower court’s decision to admit the statement. The Court reasoned that because the statement was spontaneous and not solicited, it was admissible despite Harris’s right to counsel having attached. The translator’s action of allowing Harris to speak, reasonably believing he sought clarification, did not constitute inducement.
Facts
Defendant Harris was arrested for fatally stabbing a fellow inmate at the Watertown Correctional Facility.
Before arraignment, a Spanish teacher was appointed as an interpreter for Harris due to his limited English proficiency.
The interpreter translated the Miranda warnings, which Harris indicated he understood.
Harris was not questioned by anyone.
During arraignment, after the Town Justice spoke, Harris inquired in Spanish if he could ask the interpreter something.
The translator, believing Harris had a question about the Justice’s last statement, said yes without consulting the court.
Harris then stated in Spanish that he had a nervous condition, didn’t realize he killed the man, and was guilty.
The translator immediately informed the court of Harris’s statement.
Procedural History
The trial court admitted Harris’s statement into evidence.
The Appellate Division affirmed the trial court’s decision.
Harris appealed to the New York Court of Appeals.
Issue(s)
Whether a defendant’s unsolicited confession, made in court after arraignment and attachment of the right to counsel, is admissible if the statement was spontaneous and not the product of inducement, provocation, encouragement, or acquiescence.
Holding
Yes, because the defendant’s statement was spontaneously volunteered and not the result of “inducement, provocation, encouragement or acquiescence.”
Court’s Reasoning
The Court of Appeals held that Harris’s statement was admissible because it was spontaneous and not the result of any inducement. The Court relied on the established principle that while the right to counsel attaches at arraignment, barring statements made without counsel present or a valid waiver (People v. Samuels, 49 NY2d 218), an exception exists for spontaneous statements (People v. Maerling, 46 NY2d 289, 302-303).
The Court emphasized that Harris initiated the exchange, and the translator’s response, based on a reasonable belief that Harris merely wanted clarification, did not amount to inducement. The Court cited People v. Anderson, 42 NY2d 35, 38-39, to support the finding that the statement was wholly self-generated. Further, the court noted it found spontaneity in instances where a police officer engaged in a more extensive dialogue with the defendant, referencing People v. Lynes, 49 NY2d 286. The court stated, “Defendant initiated the exchange, and the translator’s response, based on the reasonable belief that defendant merely wanted clarification of what she had just said, was neither intended nor objectively likely to elicit an inculpatory statement from defendant, who had been fully advised of his Miranda rights.”
The Court rejected the argument that an affirmative act to prevent the statement was required, stating, “We have not previously established a requirement that a defendant affirmatively be stopped from making an inculpatory statement, and we see no reason to depart from our precedents to do so on these unusual facts.” The Court affirmed that it was not retreating from the rights accorded to a defendant upon the filing of formal criminal charges, but declined to create a new rule that would ignore admissions made spontaneously in court.