Idaho v. Wass

Shawn Wass appealed the judgment entered upon his conditional guilty plea to possession of a controlled substance (methamphetamine). He argued the district court erred when it denied his motion to suppress his admission to the arresting officer that he was in possession of syringes. Wass argued the arresting officer did not inform him of his Miranda rights prior to being questioned. The trial court found the officer did not tactically induce a confession, coerce a confession, or use improper tactics to obtain the confession prior to Miranda warnings. The court found a second set of Miranda warnings did cure the failure to administer it the first time: “[i]t’s not a coercion where the actual circumstances are calculated to undermine the suspect’s ability to exercise free will. So I find that the second Miranda warnings does [sic] cure it. Once that happens, then the officer has reasonable articulable suspicion to search the automobile under the automobile search warrantless exception and he does search it and finds the items found in the case. So I’m denying the motion to suppress.” The United States Supreme Court first addressed the issue of whether admissions made in response to police questioning before Miranda warnings have the effect of rendering the same admissions made again after Miranda warnings inadmissible. Wass did not contend that either his pre- or post-Miranda statements were coerced. Therefore the Idaho Supreme Court upheld the trial court’s decisions that the post-Miranda statements were admissible. View "Idaho v. Wass" on Justia Law