State v. Rodriguez-Moreno

A defendant’s confession that leads to a felony murder conviction is voluntarily given where detectives told Defendant that they needed to know what happened to a child in order for the doctors to treat her, because, given the totality of the circumstances, the detective’s statement did not cultivate coercive circumstances.

Defendant appealed conviction of felony murder for the death of S, his girlfriend’s daughter. Defendant argued that statements made to detectives were inadmissible because they were rendered involuntary through coercion. The statements made were given when the detectives took Defendant aside at the hospital where S was awaiting medical care and told Defendant that it was important they knew what happened so that the doctors could treat S. The Court held that the statements were admissible because, under the totality of the circumstances, the detectives’ statements did not rise to the level of coercion. The detectives did not repeatedly state that Defendant must confess or the child’s medical condition would suffer, the detectives did not appeal to Defendant’s religious convictions but only to his empathy or guilt, the detectives provided Defendant with Miranda warnings, and the detectives did not offer leniency if Defendant confessed. Defendant also argued, and the Court agreed, that the trial court committed plain error when it ordered Defendant to pay attorney’s fees without considering Defendant’s ability to pay. Portion requiring Defendant to pay attorney’s fees reversed; otherwise affirmed.