Once a defendant unambiguously invokes his right to remain silent, his responses to further questioning cannot render his invocation ambiguous; state court’s contrary conclusion was an unreasonable application of Miranda v. Arizona (1966) 384 U.S. 436. After three hours of police interrogation, Jones told officers, “I don’t want to talk no more.” The officers asked a follow-up question and the interrogation continued, culminating in a confession. The trial court denied Jones’ motion to suppress the confession as obtained in violation of Miranda. Jones appealed and the state appellate court affirmed. The court reasoned that Jones did not unambiguously invoke his right to remain silent because he conversed with officers after telling them he did not want to talk to them anymore. Jones filed a federal habeas petition, which the district court denied. He appealed. Held: Reversed and remanded. Under Miranda, when a suspect invokes his right to silence, the officer’s interrogation must cease. “By continuing to interrogate Jones after his invocation, the officers squarely violated Miranda. . . . Allowing the state to use Jones’ post-invocation statements against him, even to argue that his initial invocation was ambiguous, is thus contrary to clearly established Supreme Court case law.” The error was not harmless under Brecht v. Abrahamson (1993) 507 U.S. 619 because Jones’ statements to police made after his invocation were the “backbone” of the prosecution case.
The full opinion is available on the court’s website here: https://cdn.ca9.uscourts.gov/datastore/opinions/2016/07/22/13-56360.pdf