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Name: Doody v. Schriro
Case #: 06-17161
Court: US Court of Appeals
District 9 Cir
Opinion Date: 02/25/2010
Summary

Reversal was required where the trial court failed to consider the totality of circumstances regarding the voluntariness of the defendant’s confession. The appellate court reversed the district court’s denial of a habeas corpus petition challenging convictions based on nine murders committed inside a Buddhist temple. The court held the Arizona Court of Appeals unreasonably concluded that advisements made to defendant under Miranda v. Arizona (1966) 384 U.S. 436, were clear and understandable, when the detective downplayed the warnings’ significance, deviated from an accurate reading of the Miranda waiver form, and expressly misinformed defendant regarding his right to counsel. The court further held that the state court made an unreasonable determination that the defendant, a sleep-deprived teenager, voluntarily confessed to a tag team of detectives after nearly 13 hours of overnight police interrogation. The court held the state court unreasonably applied clearly established federal law in failing to consider the totality of the circumstances to determined whether the defendant’s will was overborne by the interrogation. The court concluded the coerced confession was inadmissible and the error was not harmless.