Victoria Elizabeth Rios vs. State of Florida
This unanimous decision reverses Rios' conviction and sends the case back to trial court for a new trial. Certain statements that Rios made to law enforcement cannot be used as evidence in the new trial. The ruling reads:
"... these facts strongly suggest that law enforcement designed its tactics for no other purpose than to exhaust [Rios] into admitting her involvement in the crime. ... law enforcement used improper and deliberate tactics in delaying administration of Miranda warnings..."
The ruling states that trial court should have suppressed Interview 2.
Despite the State's denial, this should be considered a "custodial interrogation".
- A reasonable person would have felt that they could not stop or leave the interview. Law enforcement told her she couldn't leave and sent her father away, preventing her from leaving.
- It included questions designed to get an incriminating response about a specific crime.
Miranda warnings must be read before this type of interrogation.
The ruling states that trial court should have suppressed Interview 3.
Rios was read her Miranda warnings in this interview and waived her rights. When she waived Miranda, it was not done "knowingly, intelligently, and voluntarily". Many things prevented Rios from understanding the significance of the Miranda warnings:
- Law enforcement's tactics aimed to exhaust Rios into confessing. This includes delaying Miranda warnings.
- Law enforcement downplayed the importance of the Miranda warnings.
- Law enforcement denied Rios access to her father.
- Rios' age (17), her I.Q. of 75, and her lack of experience with the criminal justice system limited her understanding.
The Court also states that including Interviews 2 and 3 in her trial was not harmless.
Without these interviews, there was not compelling evidence that she was involved.
At the time of the interrogation in this case, Rios was a 17-year-old runaway. She was involved in an armed burglary where the homeowner was killed. The victim was shot and stabbed by two of her accomplices.
Police searched the home of one of her accomplices. Everyone in the home, including Rios, was asked to go to police station for questioning. Rios went voluntarily.
Once there, she was isolated in an interview room 11 hours. She was interviewed 3 times, with long stretches alone. She was specifically told she could not leave until her father arrived. When he got there, law enforcement told him to leave without seeing her.
During Interview 2, the questioning became accusatory. Rios admitted she knew of the plan to rob the victim, but said she did not go into the home. She claimed she didn't know of the victim's death until later.
She was received Miranda warnings during Interview 3, over 9 hours after she arrived in the interview room. She then confessed to being in the victim's home during the crime.
At trial, she asked that Interviews 2 and 3 be suppressed. In Interview 2, she was not given the Miranda warnings during a custodial interrogation. In Interview 3, she was told her rights but did not understand the importance. The trial court allowed the interviews into evidence.