People v. Perdomo, 26 N.Y.3d 68 (2015)
A voluntary statement made by a defendant after invoking their right to remain silent under Miranda can be used for impeachment purposes if the defendant later testifies inconsistently at trial.
Summary
The New York Court of Appeals addressed whether statements made by a defendant after invoking their Miranda rights can be used for impeachment if the defendant later testifies at trial. The court held that such statements are admissible for impeachment as long as they were voluntarily made. The court declined to adopt a rule that would automatically exclude all post-invocation statements, even if voluntary. The court affirmed the lower court’s ruling that the defendant’s statements were voluntary and thus admissible for impeachment, as there was no evidence that the police intentionally coerced the statements.
Facts
The defendant was arrested for a shooting and read his Miranda rights, which he invoked. However, during questioning, the police made statements suggesting the defendant knew his co-defendant, and the defendant responded by denying the co-defendant had shot himself. The prosecution sought to use the defendant’s post-Miranda statements for impeachment if he testified. The trial court denied the defendant’s motion to preclude the use of these statements. The defendant did not testify at trial but was convicted of several charges. The Appellate Division affirmed the trial court’s decision that the statements were admissible for impeachment. The defendant appealed to the Court of Appeals.
Procedural History
The trial court denied the defendant’s motion to preclude the use of post-Miranda statements for impeachment. The Appellate Division affirmed. The Court of Appeals granted leave to appeal.
Issue(s)
1. Whether a statement made by a defendant to police after invoking their Miranda rights can be used for impeachment purposes if the statement was voluntary.
Holding
1. Yes, because voluntary statements made by a defendant after invoking their Miranda rights can be used for impeachment purposes if the defendant later testifies inconsistently.
Court’s Reasoning
The court began by restating the general rule that statements obtained in violation of Miranda cannot be used in the prosecution’s case-in-chief. However, drawing on the precedent of Harris v. New York, the court reiterated that such statements may be used for impeachment purposes if the defendant testifies at trial and makes statements inconsistent with the prior statement. The court declined to adopt a bright-line rule that would prohibit the use of all post-invocation statements for impeachment, because it would effectively permit perjury by defendants. The court emphasized the importance of voluntariness, finding that the defendant’s statements were voluntary. The court noted that the police did not overreach, and there was no evidence that the investigators deliberately tried to get around the defendant’s rights. The court found nothing in the record to suggest that the police deliberately sought to circumvent the defendant’s invocation of his rights.
Practical Implications
This case reinforces the principle that a defendant’s voluntary post-Miranda statements can be used for impeachment, even if they are not admissible in the prosecution’s direct case. This ruling is important for attorneys and legal practitioners because it affects how they advise their clients during custodial interrogations. Prosecutors can still use voluntary statements obtained after a defendant asserts their right to silence if the defendant later offers inconsistent testimony at trial. Defense attorneys must consider the possibility that any statements their client makes, even after invoking Miranda, could be used against them if they choose to testify. The case underscores the importance of assessing the voluntariness of any statements made by the defendant and considering the implications for cross-examination. The case underscores the principle that a defendant cannot use the exclusionary rule to shield themselves from impeachment by prior inconsistent statements. The rule encourages truthful testimony.