State v. Vasquez-Gonzalez

It is the State’s burden to show that a defendant “knowingly, intelligently, and voluntarily waived his Miranda rights.” State v. Ward, 367 Or 188, 191, 475 P3d 420 (2020). The knowing and intelligent inquiry “focuses primarily on a defendant’s state of mind.” State v. Norgren, 287 Or App 165, 169, 401 P3d 1275 (2017), rev dismissed, 363 Or 40 (2018).

Defendant appealed a judgment of conviction for unlawful possession of methamphetamine.  Defendant assigned error to the trial court’s denial of his motion to suppress his incriminating statements.  On appeal, Defendant argued that “he did not knowingly and intelligently waive his Miranda rights.”  In response, the State asserted that Defendant did knowingly and intelligently waive his Miranda rights.  It is the state’s burden to show that a defendant “knowingly, intelligently, and voluntarily waived his Miranda rights.”  State v. Ward, 367 Or 188, 191, 475 P3d 420 (2020).  The knowing and intelligent inquiry “focuses primarily on a defendant’s state of mind.”  State v. Norgren, 287 Or App 165, 169, 401 P3d 1275 (2017), rev dismissed, 363 Or 40 (2018).  The Court found that there was sufficient evidence for the trial court to conclude that Defendant “was capable of understanding and, subsequently, knowingly and intelligently waiving, his Miranda rights.”  The Court held that the trial court did not err when it denied Defendant’s motion to suppress.  Affirmed.