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Name: Reyes v. Lewis
Case #: 12-56650
Court: US Court of Appeals
District 9 Cir
Opinion Date: 08/14/2015
Summary

California Court of Appeal’s affirmance of trial court’s decision to not suppress statement obtained in violation of Missouri v. Seibert (2004) 542 U.S. 600 was contrary to clearly established federal law. Reyes was convicted of the first degree murder of Ochoa, which occurred when Reyes was 15 years old. After the murder, police questioned Reyes in a series of interviews and he agreed to take a polygraph test. The police did not give Reyes Miranda warnings during any of these initial interviews and he confessed after being told that he “failed” the polygraph test. Police then drove Reyes to a different police station and read Reyes his Miranda rights. He agreed to talk to police and repeated his confession. The trial court suppressed Reyes’s unwarned confession, but not the post-warning confession. The California Court of Appeal found the operative question was whether Reyes’s post-warning statement was voluntary, and did not fully analyze whether the two-step interrogation method violated Seibert. Reyes’ state habeas petitions were denied. The district court denied his federal habeas petition and he appealed. Held: Reversed. For purposes of AEDPA, the clearly established rule under Seibert is that if officers deliberately employ the two-step interrogation technique of interrogating in successive unwarned and warned phases, and if insufficient curative measures are taken to ensure that later Miranda warnings are genuinely understood, any warned statement thereby obtained must be suppressed, even if the statement is voluntary. Here, the State court only analyzed whether Reyes’s post-polygraph and post-warning statements were voluntary, which is irrelevant under Seibert. The court’s findings were contrary to clearly established federal law and thus due no deference under AEDPA. The objective evidence reflected that the officers deliberately employed the prohibited interrogation technique and did not undertake sufficient curative measures to ensure that Reyes understood the import and effect of his Miranda waiver.