State of Tennessee v. Devin Jefferson

Citation: Not availableDocket: W2010-01600-CCA-R3-CD

Court: Court of Criminal Appeals of Tennessee; October 27, 2011; Tennessee; State Appellate Court

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Devin Jefferson was convicted of first-degree felony murder during an attempted robbery and sentenced to life in prison. He appealed, claiming the trial court erred by not suppressing his police statement, arguing that police continued to interrogate him after he invoked his right to remain silent and requested counsel, and that his statement was coerced. The Court, after reviewing oral arguments, records, and briefs, affirmed the trial court's judgment.

The factual background indicates that in April 2008, a Shelby County Grand Jury indicted Jefferson and three others for the murder of Taylor Bradford, a University of Memphis student. Jefferson, who was also a student at the university, had conspired with his co-defendants to rob Bradford after hearing about his display of cash. On September 29, 2007, following their plan, Jefferson used a parking permit to access the victim's apartment complex and directed his co-defendants on where to find Bradford. The robbery attempt escalated when one co-defendant shot the victim, who later died in a car crash after being shot in the chest. The evidence presented at trial was deemed sufficient to uphold the conviction.

The police arrested the appellant following an investigation that implicated him through his co-defendants. On October 8, 2007, the appellant was arrested at Bell's apartment. Initially, he refused to waive his rights but later provided a statement to Sergeants Mundy Quinn and Ron Collins, which was recorded and entered into evidence. In this statement, the appellant claimed that the robbery of the victim was his idea, planned in his dorm room on September 29. On September 30, after returning home from work, he was picked up by Bell, and they later went to her apartment. During this time, he received multiple calls from co-defendant Tate, who also contacted the victim. The appellant claimed he was unaware of any intent to kill the victim.

Cellular phone records from the night of the crime indicated multiple calls between the appellant and Tate, as well as calls between Tate and the victim. Bell confirmed that she picked up the appellant around 7:00 p.m. and that he received two phone calls while at her apartment. She stated that the appellant seemed upset upon learning she had visited the victim at the hospital later that night. Testimony from Tate and Trezevant at trial indicated that the appellant planned the robbery. Consequently, the jury convicted him of first-degree felony murder during the attempted robbery, leading to a life sentence.

The appellant subsequently filed a motion to suppress his statement, arguing that police continued to interrogate him after he invoked his rights and that the statement was coerced. The State argued that the trial court correctly denied the motion. At the suppression hearing, Sergeant Eric Freeman testified regarding the investigation that identified the appellant as a suspect.

During the investigation related to a robbery involving Taylor Bradford, several individuals implicated Devin Jefferson as orchestrating the crime. On October 8, the police arrested the appellant at Erica Bell's apartment without a warrant. He was taken to the police department and placed in an interview room. At approximately 1:00 p.m., Sergeants Quinn and Collins conducted an interview, during which the appellant acknowledged understanding his rights but declined to speak, citing a potential need for an attorney as advised by his mother. Following this, they informed Lieutenant Armstrong of the refusal, who directed them to charge the appellant with first-degree murder. Upon learning of the charges, the appellant expressed a desire to provide a statement, subsequently waiving his rights and signing the Advice of Rights form. During the interview, Sergeant Quinn testified that he did not threaten or promise the appellant anything and noted that the appellant was not free to leave the room. Although the interview was not recorded, Sergeant Quinn documented a summary afterward. He confirmed that during preliminary hearings, he indicated the appellant had requested legal counsel.

Sergeant Quinn did not review the appellant's supplement or statement before the preliminary hearing. During redirect examination, he clarified that he interpreted the appellant's mention of an attorney as a request for counsel, prompting him to stop the interview. The appellant testified about his arrest at Bell’s apartment on October 8, describing being handcuffed with guns drawn, waiting in a police car for at least an hour, and then being taken to an interrogation room where he was shackled to a chair. After falling asleep, he read and signed an Advice of Rights form, indicating he understood his rights and initially responding 'no' when asked if he wished to talk, while also stating he did not want to speak without an attorney. 

Lieutenant Armstrong later entered the room, making threatening remarks about potential charges and consequences, which the appellant perceived as coercive. Despite asking for a phone to call an attorney, his request was denied, and the officers allegedly pressured him into giving a statement by stating he would not get to use the phone unless he cooperated. On cross-examination, the appellant reiterated his desire to remain silent and request for a phone. 

The trial court denied the appellant’s motion to suppress his statement, crediting Sergeant Quinn's assertion that the appellant made an equivocal request for counsel, which did not obligate the officers to cease questioning. The court noted that while Quinn treated the request seriously, he also found that the officers returned to inform the appellant of the charges rather than to re-initiate questioning. The appellant's subsequent statement was deemed spontaneous after he expressed a desire to clarify his innocence.

The trial court assessed the credibility of the appellant's claims regarding coercion during police interrogation, determining that the appellant's testimony was not credible. The court specifically noted that the alleged harassment and related discussions could not have occurred within the brief time frame of 1:10 to 1:14 p.m. Consequently, the court concluded that the appellant chose to speak with the officers voluntarily, motivated by his desire to distance himself from the robbery, rather than due to coercion from the officers. The court found that the appellant validly waived his rights, giving his statement freely.

In evaluating the appellant's motion to suppress based on alleged violations of his right to remain silent, the court referenced protections under the Fifth Amendment and the Tennessee Constitution against self-incrimination. It emphasized that once an individual indicates the desire to remain silent, interrogation must cease. The definition of "interrogation" extends beyond direct questioning to any police actions likely to elicit an incriminating response, focusing on the suspect's perspective rather than the police's intent. Prior case law was cited to illustrate these principles, including State v. Crump and State v. Sawyer, highlighting the importance of ensuring that police conduct does not coerce a confession and the procedures surrounding the reading of Miranda warnings.

Determining whether the reading of the affidavit constituted an "interrogation," the supreme court referenced various cases where informing a defendant of charges did not equate to interrogation, including instances where the accused was advised of specific charges without additional engagement. The trial court credited Sergeant Quinn’s testimony, noting that after reading Miranda rights, the appellant invoked his right to remain silent. The officers ceased questioning but later informed the appellant of the murder charge without further discussion. The appellant then spontaneously stated he did not shoot the victim and wanted to give a statement, changing his response on the Advice of Rights form. The trial court concluded that the officers’ notification of the charge did not amount to interrogation, thereby denying the motion to suppress. Additionally, the appellant argued that his right to counsel was violated when police continued to interrogate him post-invocation. However, since it was established that the initial notification of the charge was not an interrogation, this point was addressed for potential appellate review. The excerpt underscores the protections against self-incrimination under the Fifth Amendment and relevant state provisions.

Once a suspect requests an attorney, interrogation must stop, and further questioning is prohibited until counsel is provided, unless the suspect initiates further communication. The standard for determining a valid invocation of the right to counsel is consistent under both the U.S. and Tennessee constitutions. The accused must clearly articulate the desire for counsel so that a reasonable officer would understand it as such. Ambiguous statements do not invoke this right, allowing police to continue questioning without needing clarification. In this case, the trial court deemed the appellant's statement about needing an attorney as equivocal, which aligns with precedent indicating that vague requests do not necessitate a halt in questioning. Although Sergeant Quinn initially interpreted the appellant's statement as a clear request for counsel and ceased questioning, the appellant acknowledged that once he invoked his right to remain silent, the officers stopped all questioning. Thus, there was no violation of his Fifth Amendment rights.

Additionally, the appellant argued that his confession was coerced due to the circumstances of his arrest and interrogation, claiming he was subjected to a coercive environment and had insufficient time to review his rights. However, if a suspect is informed of their Miranda rights and voluntarily waives those rights, they can waive the privilege against self-incrimination. The conditions of the interrogation, while extreme, do not inherently invalidate the waiver if it was made knowingly and voluntarily.

A waiver's validity, determined by the totality of circumstances surrounding the interrogation, must be voluntary, knowing, and intelligent according to precedent. The evidence supports the trial court's findings, as it is the trier of fact capable of assessing witness credibility and resolving evidentiary conflicts. Sergeant Quinn testified that he informed the appellant of the murder charge, noted the appellant's denial of shooting the victim, and confirmed the appellant's acknowledgment of his rights by marking and signing the Advice of Rights form. The appellant admitted to understanding his rights at the suppression hearing and was informed about potential co-defendants' charges only after waiving his rights. The trial court rejected the appellant's claims of coercion, finding that the alleged harassment could not have occurred in the short interrogation duration and that he did not assert that being shackled or lack of basic needs influenced his statement. Consequently, the motion to suppress was properly denied, and the trial court's judgment was affirmed.