Berghuis v. Thompkins Case Brief

Facts of the case

A Michigan state court convicted Van Chester Thompkins of first-degree murder, assault with intent to commit murder, and several firearms related charges. After exhausting his remedies in Michigan state court, Thompkins petitioned for habeas corpus relief in a Michigan federal district court. The district court denied the petition.On appeal, Thompkins argued that his confession was obtained in violation of the Fifth Amendment and that he was denied effective counsel at trial. The Sixth Circuit held that the Michigan Supreme Court’s finding that Thompkins waived his Fifth Amendment right was unreasonable because Thompkins refused to sign an acknowledgement that he had been informed of his Miranda rights and rarely made eye contact with the officer throughout the three hour interview. The Sixth Circuit also held that the Michigan Supreme Court improperly determined that Thompkins was not prejudiced by his counsel’s failure to request a limiting instruction related to his separately tried co-defendant’s testimony.

CONCLUSION

The Court found that Thompkins did not say that he wanted to remain silent or that he did not want to talk with the police. Had he made either of those simple, unambiguous statements, he would have invoked his right to cut off questioning. He did neither, so he did not invoke his right to remain silent. There was no basis to conclude that he did not understand his rights and it followed that he chose not to invoke or rely on those rights when he did speak. His answer to a detective’s question about whether he prayed to God for forgiveness for shooting the victim was a course of conduct indicating waiver of the right to remain silent. If Thompkins wanted to remain silent, he could have said nothing in response to the detective’s questions, or he could have unambiguously invoked his Miranda rights and ended the interrogation. The fact that Thompkins made the statement about three hours after receiving a Miranda warning did not overcome the fact that he engaged in a course of conduct indicating waiver. There was no evidence that the statement was coerced. It was not reasonably likely that a jury instruction would have made any difference in light of all the other evidence of guilt.

  • Advocates: B. Eric Restuccia Solicitor General, Lansing Michigan, for the petitioner Nicole A. Saharsky Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae supporting the petitioner Elizabeth L. Jacobs on behalf of the respondent
  • Petitioner: Mary Berghuis, Warden
  • Respondent: Van Chester Thompkins
  • DECIDED BY:Roberts Court
  • Location: –
Citation: 560 US 370 (2010)
Granted: Sep 30, 2009
Argued: Mar 1, 2010
Decided: Jun 1, 2010
Berghuis v. Thompkins Case Brief