LOCATION: Private Residence
DOCKET NO.: 10-1540
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Sixth Circuit
CITATION: 565 US (2011)
GRANTED: Nov 07, 2011
DECIDED: Nov 07, 2011
Facts of the case
On September 22nd, 1993, Archie Dixon and Timothy Hoffner arrived at the Toledo home of Kirsten Wilkerson. Christopher Hammer was staying at Wilkerson’s house. Upon arriving at Wilkerson’s house, Dixon and Hoffner beat up Hammer, tied him to a bed, and robbed him. After restraining Hammer, Dixon and Hoffner proceeded to kill Hammer by burying him alive.
After burying Hammer alive, Dixon used Hammer’s birth certificate and social security card to obtain a state identification card in Hammer’s name. He used the new ID to obtain a duplicate auto title to Hammer’s car. He then sold Hammer’s car to a dealer for $2,800.
On November 4th, a police detective spoke with Dixon at a local police station in a chance encounter. The detective issued Miranda warnings to Dixon and asked to talk to him about Hammers disappearance; Dixon declined to discuss the disappearance. In the course of the investigation into Hammer’s disappearance, the police discovered that Dixon had sold Hammer’s car and forged Hammer’s signature when cashing the check he received in the sale. On November 9th, the police detained Dixon and charged him with forgery.
The police questioned Dixon without reading him his Miranda rights. The focus of the questioning was Hammer’s disappearance and not Dixon’s alleged act of forgery. Dixon asserted his right to have an attorney present, but the police continued to question Dixon without an attorney. Dixon admitted to the auto title forgery but said that he had no knowledge of Hammer’s disappearance. Later that day, Hoffner led the police to Hammer’s body. The police interviewed Dixon again. They did not inform Dixon of his Miranda rights until the second session because they feared Dixon would request counsel. Dixon confessed to the kidnapping, robbery, and murder.
At trial, Dixon was convicted and sentenced to death for murder, robbery and kidnapping. The Appellate Court and the Supreme Court of Ohio affirmed the conviction. Dixon appealed to the Court of Appeals of the Sixth Circuit, and Judge Gilbert Merritt, writing for the majority, held that the police should have terminated the forgery interrogation when Dixon requested counsel. The court also held that the police’s planned refusal to read Dixon his Miranda rights during the first session of his interrogation for murder was unconstitutional. It further held that Dixon’s were not “voluntary”.
Did the Toledo police violate Dixon’s constitutional rights by failing to read his Miranda rights during the forgery questioning?
Did the police violate the constitution by delaying the reading of Dixon’s Miranda rights until the second session of his interrogation for murder?
Were Dixon’s relevant confessions and statements voluntary?