72 N.Y.2d 836 (1988)
A defendant’s statements to interrogating officers are admissible if the defendant knowingly, intelligently, and voluntarily waived their right to counsel, and the lower courts’ factual findings supporting this waiver are supported by evidence.
Summary
This case concerns the admissibility of statements made by Publio Santiago to a prosecutor during interrogation. The New York Court of Appeals affirmed the Appellate Division’s order upholding the trial court’s denial of Santiago’s motion to suppress those statements. The Court of Appeals found that the trial court’s undisturbed findings indicated that Santiago, a mature and well-educated individual, had not refused to speak, had not explicitly requested a lawyer, and was not coerced. Therefore, he knowingly and voluntarily waived his right to counsel. Because there was evidence to support the lower courts’ findings, the Court of Appeals deferred to those findings and affirmed the conviction.
Facts
Publio Santiago was interrogated by a prosecutor. He subsequently sought to suppress the statements he made during that interrogation. The specific details of the interrogation (the specific questions asked, the exact nature of the statements) are not detailed in the opinion, as the core issue revolved around whether Santiago had invoked his right to counsel.
Procedural History
The trial court held a Huntley hearing to determine the admissibility of Santiago’s statements. The trial court denied the motion to suppress, finding that Santiago had knowingly and voluntarily waived his right to counsel. Santiago was subsequently convicted. The Appellate Division affirmed the conviction. The case then went to the New York Court of Appeals, which affirmed the Appellate Division’s order.
Issue(s)
Whether the lower courts erred in concluding that Santiago failed to invoke his right to counsel, thereby making his statements to the interrogating prosecutor admissible.
Holding
No, because the trial court’s findings, undisturbed by the Appellate Division, were supported by evidence that Santiago did not refuse to speak, did not explicitly request a lawyer, was not coerced, and knowingly, intelligently, and voluntarily waived his right to counsel.
Court’s Reasoning
The Court of Appeals emphasized the importance of deferring to the factual findings of the lower courts, especially when those findings are supported by evidence. The court noted that the trial court specifically found that Santiago was a mature, intelligent, and well-educated defendant. Based on these characteristics and the circumstances of the interrogation (no refusal to speak, no explicit request for counsel, no coercion), the trial court concluded that Santiago had waived his right to counsel. The Appellate Division did not disturb these findings. The Court of Appeals held that it could not say, as a matter of law, that the lower courts were wrong. The court implicitly applied the standard of review that requires deference to factual findings unless they are clearly erroneous or unsupported by the record. The court stated, “There being evidence to support the undisturbed findings, we cannot say as a matter of law that the lower courts were wrong in concluding defendant failed to invoke his right to counsel with respect to the statements by defendant to the interrogating prosecutor.” The court’s decision underscores the principle that the determination of whether a defendant has knowingly and voluntarily waived their right to counsel is heavily fact-dependent and that appellate courts will generally defer to the findings of the trial court, which is in the best position to assess the credibility of witnesses and weigh the evidence.