People v. McQueen, 18 N.Y.2d 342 (1966)
The Supreme Court’s decision in Miranda v. Arizona does not apply retroactively to trials that commenced before the Miranda decision was announced, unless the issue of voluntariness of the confession is properly raised.
Summary
The New York Court of Appeals addressed whether the Supreme Court’s landmark decision in Miranda v. Arizona should be applied retroactively to a trial that commenced before the Miranda ruling. McQueen was convicted of murder in 1964, and on appeal, she argued that her pre-arraignment confessions should have been excluded because she was not given Miranda warnings. The court held that Miranda did not apply retroactively to trials commenced before the Miranda decision, unless the issue of the voluntariness of the confession was raised at trial. Since McQueen did not properly raise the issue of voluntariness, her conviction was affirmed.
Facts
Following an altercation at a bar, McQueen stabbed the victim outside the bar. The incident occurred around 3:00 a.m. on November 20, 1960. The victim’s body was discovered shortly after. McQueen resided near the bar. Upon returning to her apartment, McQueen told a roommate that she had committed the homicide. The following morning she told her daughter that she had “cut a man” because he kicked her. McQueen was taken to the police station about three hours after the discovery of the body. Within minutes, she confessed to the crime. She then accompanied the police to her apartment and showed them the knife she used. She re-enacted the crime at the scene of the homicide.
Procedural History
McQueen was tried and convicted of second-degree murder in a trial that commenced on November 9, 1964. She appealed, arguing that her pre-arraignment confessions and re-enactment of the crime should have been excluded because she was not given Miranda warnings. The Appellate Division affirmed her conviction. McQueen then appealed to the New York Court of Appeals.
Issue(s)
Whether the ruling in Miranda v. Arizona, which requires that suspects be informed of their rights before custodial interrogation, applies retroactively to trials that commenced before the Miranda decision was announced.
Holding
No, because the Supreme Court in Johnson v. New Jersey held that the Miranda decision applies only to trials that began after the date of the Miranda decision, June 13, 1966, unless the issue of voluntariness of the confession was properly raised at trial.
Court’s Reasoning
The court emphasized that the Supreme Court in Johnson v. New Jersey determined that Miranda should only apply to trials that began after the decision was announced. The court acknowledged that state courts could apply a greater measure of retroactivity than the Supreme Court required. However, the court declined to do so in this case, noting that law enforcement agencies had fairly relied on prior decisions in obtaining incriminating statements before Escobedo and Miranda. The court stated: “these decisions should apply only to trials begun after the decisions were announced * * * even though the cases may still be on direct appeal” (384 U. S. 732-733). The Court noted that the defense counsel did not object to the admission of the confessions on the grounds that they were involuntarily made. The Court noted that the motions to suppress the statements were based on the Escobedo decision and on failure to give warnings afterwards held necessary in Miranda. The court found there was no indication of involuntariness in McQueen’s confession. Although a detective told McQueen she might as well admit what she did, mere deception is not enough to render a confession involuntary. The court noted that McQueen’s intoxication and mental state were considered by the jury as bearing upon the truth of her statements, but not the voluntariness, which was not at issue. Therefore, the court held that Miranda did not apply retroactively in this case, and affirmed McQueen’s conviction.