Statements by police officers to a defendant during interrogations, in which the officers implied that if the defendant told the truth he might be able to avoid the death penalty, did not amount to impermissible promises of leniency in exchange for a confession. Further, Miranda warnings were not required during an earlier interrogation because the defendant was not in custody, even though his parole officer had placed him in handcuffs while awaiting the arrival of homicide detectives. The detectives themselves did not order that he be handcuffed, and upon finding him in that state ordered that he be uncuffed immediately. The court found that a reasonable person, whether or not the person was a parolee, would not have believed that he was in custody under those circumstances.
Case Summaries