People v. Washington, 51 N.Y.2d 214 (1980)
A defendant’s prior inconsistent statements, even if suppressed due to a Miranda violation, can be used to impeach their credibility at trial, provided the trustworthiness of the evidence satisfies legal standards, but a pretrial finding that the defendant did not make the statement does not automatically bar its use for impeachment.
Summary
The New York Court of Appeals addressed whether a defendant’s suppressed statements, obtained in violation of Miranda rights, could be used to impeach his trial testimony. The defendant argued that the pretrial suppression court’s finding that he did not make the statements barred their use for any purpose. The Court of Appeals held that such statements could be used for impeachment if trustworthy, and the determination of whether the defendant made the statement is a factual question for the jury. The court emphasized that the ‘trustworthiness’ standard does not require a pretrial determination that the defendant made the statement, and that any dispute on this point is a matter for the jury.
Facts
Police officers, investigating a report of a man with a gun, found the defendant asleep on a couch with a gun in his pocket. The defendant allegedly made two inconsistent statements about the gun’s origin: first, that he found it in a car, and later, that his wife planted it on him.
Procedural History
Prior to trial, the defendant moved to suppress the statements, claiming a violation of his constitutional rights. The suppression court found the arresting officer’s testimony regarding the statements not credible and granted the motion to suppress. At trial, the court allowed the prosecution to use the suppressed statements to impeach the defendant’s testimony. The jury convicted the defendant. The Appellate Division affirmed. The dissenting justice granted leave to appeal.
Issue(s)
1. Whether a defendant’s statements, suppressed due to a Miranda violation, can be used to impeach their credibility at trial under Harris v. New York.
2. Whether a pretrial finding that the defendant did not make the suppressed statements bars their use for impeachment.
Holding
1. Yes, because statements obtained in violation of Miranda, though inadmissible as evidence in chief, may be used to impeach the defendant’s credibility, provided they are trustworthy.
2. No, because the determination of whether the defendant made the statement is a factual question for the jury to resolve.
Court’s Reasoning
The court relied on Harris v. New York, which allows the use of statements obtained in violation of Miranda for impeachment purposes, provided they are trustworthy. The court clarified that ‘trustworthiness’ in this context primarily relates to voluntariness (i.e., the statements were not the product of coercion or duress). The court emphasized the traditional rule that any dispute over whether the defendant made the statement is a factual issue for the jury. “Traditionally, of course, any dispute as to whether the defendant made the statement would present a factual question for the jury to resolve.” The court distinguished the case from situations where the prosecution knowingly uses perjured testimony, which violates the defendant’s due process rights. However, a disputed claim of fabricated evidence involving only witness credibility can be resolved by the jury. The court reasoned that extending pretrial suppression hearings to encompass claims of fabricated evidence would be an unwarranted expansion of the exclusionary rule. The court stated, “The purpose of the court’s decision in that case was not to alter the rules of evidence with respect to prior inconsistent statements but rather to preserve one of ‘the traditional truth-testing devices of the adversary process’.”