People v. Hopkins, 58 N.Y.2d 1079 (1983)
A delay in arraignment, absent extraordinary circumstances, is merely a factor to consider regarding the voluntariness of a confession and does not automatically trigger the right to counsel.
Summary
Hopkins was convicted of multiple crimes, including murder. He challenged the admissibility of his pre-arraignment confessions, arguing they were involuntary due to a delay in his arraignment and a violation of his right to counsel. The New York Court of Appeals affirmed the conviction, holding that the delay in arraignment was justified by the unexpected revelations of unsolved murders during questioning, and the defendant knowingly waived his right to counsel. The court also found that a later confession to a deputy sheriff was spontaneous and admissible. The court found any error regarding cross-examination was harmless and prosecutorial misconduct did not deprive defendant of a fair trial.
Facts
Hopkins was arrested and gave oral and written confessions before arraignment. During questioning, Hopkins revealed information about two previously unsolved murders. His arraignment was postponed due to these revelations. Hopkins was offered counsel before arraignment but declined. After being remanded to the county jail, Hopkins made another confession to a deputy sheriff. At trial, Hopkins testified and was cross-examined about a collateral matter elicited at the Huntley hearing.
Procedural History
The trial court found Hopkins’s confessions admissible. Hopkins was convicted. The Appellate Division affirmed. The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
Issue(s)
1. Whether the pre-arraignment confessions were involuntary due to a delay in arraignment and a violation of the right to counsel.
2. Whether the confession to the deputy sheriff was admissible.
3. Whether cross-examination about a collateral matter violated Hopkins’s privilege against self-incrimination.
4. Whether prosecutorial misconduct deprived Hopkins of a fair trial.
Holding
1. No, because the delay in arraignment was justified by the unexpected revelations concerning two unsolved murders, and Hopkins knowingly declined pre-arraignment offers of counsel.
2. Yes, because the confession was spontaneous.
3. No, because even if it was an error, it was harmless.
4. No, because, though the prosecutor’s conduct was not exemplary, it did not deprive Hopkins of a fair trial.
Court’s Reasoning
The Court of Appeals reasoned that the finding that the confessions were voluntary had support in the record and was beyond their review. The court cited People v. Anderson and People v. Leonti to support this proposition. The court emphasized that a delay in arraignment is only one factor in determining voluntariness, absent extraordinary circumstances, citing People v. Holland and People v. Dairsaw. The unexpected revelations about the two unsolved murders justified postponing the arraignment. The court distinguished People v. Lockwood, noting the justification for the delay.
The court determined the Donovan-Arthur rule was not applicable, because counsel had not yet entered the picture at the time of the pre-arraignment confessions. The court highlighted the lower court’s finding that Hopkins, an intelligent 29-year-old and former criminology student, personally declined pre-arraignment offers of counsel, citing People v. Angus.
Regarding the confession to the deputy sheriff, the court stated that not all remarks by law enforcement constitute impermissible interrogation, citing People v. Lynes and People v. Garofolo. The court found sufficient support in the record for the finding of spontaneity, citing People v. Rivers and People v. Roucchio.
Addressing the cross-examination issue, the court deemed any error harmless because the properly admitted detailed confessions and corroborative circumstantial evidence presented an overwhelming case of guilt. The court cited People v. Crimmins, emphasizing that there was no reasonable possibility that the evidence contributed to the conviction.
Finally, the court acknowledged that the prosecutor’s conduct was not ideal but concluded that Hopkins was not deprived of a fair trial, citing People v. Galloway.