Victoria Elizabeth Rios vs. State of Florida
This unanimous decision reverses Rios' conviction of 1st degree murder and armed burglary of a dwelling. It 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..."
This court finds that Interview 2 should have been considered a "custodial interrogation", and not used at trial. Miranda warnings must be read before this type of interrogation, but was not done in this case.
- A reasonable person would have felt that they could not stop or leave the interview. Law enforcement told her she couldn't leave until her father arrived. When he arrived, they sent him away, which stopped her from leaving. She was in a locked room on video surveillance and was required to have an escort in the building. Law enforcement was also slow to allow her to use the restroom.
- Interview 2 was accusatory and included questions designed to get an incriminating response about a specific crime.
For 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". This Court finds that Interview 3 should have been suppressed, because Rios was prevented from understanding the significance of the Miranda warnings:
- Law enforcement's tactics aimed to exhaust Rios into confessing. This includes delaying Miranda warnings in Interview 2. In total she was confined for over 9 hours. Multiple law enforcement officers came in to confront her with alleged inconsistencies with her story. When she said she needed "to go to sleep", law enforcement told her to use a chair or the floor. She slept on the floor until the 3rd interview began.
- Law enforcement downplayed the importance of the Miranda warnings.
- Rios' age (17), being denied access to her father, her I.Q. of 75, and her lack of experience with the criminal justice system limited her understanding.
The Court finds that including Interviews 2 and 3 as evidence in her trial was not harmless. Without these interviews, there was no compelling evidence that she was involved with the crimes. They ordered a new trial for Rios, where Interviews 2 and 3 could not be used as evidence.
At the time of the interrogation in this case, Rios was a 17-year-old runaway. She was alleged to have been involved in an armed burglary where the homeowner was killed. The victim was shot and stabbed by two of her acquaintances.
Police searched the home of one of her acquaintances. 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 for Interviews 2 and 3 to 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 them. The trial court allowed the interviews into evidence. Rios appeals her conviction based on that decision.
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