SASHTRI AARON HARNANAN, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Sashtri Aaron Harnanan was convicted of first-degree murder and carjacking. On appeal, he challenged the admission of statements he made to a corrections officer while in custody, arguing they resulted from improper custodial interrogation without a Miranda re-warning. The appellate court affirmed, holding that Harnanan initiated the conversation and was not subjected to interrogation.
The trial court properly admitted the statements because Harnanan initiated the further communication with the officer, and the conversation did not constitute custodial interrogation. Harnanan's Fifth Amendment rights were not violated because he initiated contact, a waiver could be found, and he was not subjected to interrogation as defined by Miranda.
[1] A defendant's statements made to a corrections officer while in custody are admissible if they are not the product of an improper custodial interrogation.
[2] A waiver of Fifth Amendment rights can be found when a defendant initiates further communication and conversation with law enforcement after invoking the right to counsel…
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“it is undisputed that it was Harnanan who initiated the further communication and conversation with Price and thus a waiver of his Fifth Amendment rights could be found”
Establishes that defendant's initiation of contact can constitute a waiver of previously invoked right to counsel
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceHarnanan was arrested on June 21, 1997, and properly read his Miranda rights, after which he invoked his right to counsel. Two days later while in the…
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COBB, J.
The appellant, Sashtri Aaron Harnanan, was convicted of first degree murder and car jacking. He raises multiple points on appeal, only one of which merits extended consideration and an opinion by this court. His fourth point contends that the trial court erred in admitting into evidence statements he made to a corrections officer while in custody. The issue is whether these statements arose from improper custodial interrogation.
At trial a hearing was held outside the presence of the jury revealing that Harna-nan, after his arrest on June 21, 1997, was properly read his Miranda rights and invoked his right to counsel, who was appointed for him. Thereafter, he was held in the Orange County jail where one Nigel Price was a corrections officer. Two days after his arrest, Harnanan asked Price to place him in a bigger cell, and Price did so. Harnanan thanked Price and asked him to come back later and talk to him. At that point, Price said he could not give Harna-nan legal advice. Later, when Price returned to the cell Harnanan observed that Price appeared to be “cool” and stated that he did not know what to do about the murder charge against him. Price asked him if he would like to talk about it, but did not reread any Miranda warnings to Harnanan. A conversation then ensued during which Harnanan incriminated himself.
The trial court concluded that Harnanan had initiated contact with Price and that there was no interrogation since Price had merely “indulged” Harnanan’s expressed wish to discuss the case. The trial court found that there was no violation of Har-nanan’s free will by any subterfuge, force, threats, or any type of coercion or trickery; hence, Harnanan’s motion to suppress was denied and his statements were admitted into evidence at trial.
We affirm based upon the following principles. First, it is undisputed that it was Harnanan who initiated the further communication and conversation with Price and thus a waiver of his Fifth Amendment rights could be found. See Minnick v. Mississippi 498 U.S. 146, 156, 111 S.Ct. 486, 112 L.Ed.2d 489 (1990); Oregon v. Bradshaw, 462 U.S. 1039, 103 S.Ct. 2830, 77 L.Ed.2d 405 (1983); Edwards v. Arizona, 451 U.S. 477, 101 S.Ct. 1880, 68 L.Ed.2d 378 (1981). Second, the trial court’s factual finding that the conversation between Harnanan and Price was not an interrogation is supported by the recoi'd. Harnanan was not subjected to a custodial interrogation when he spoke to Price. See Rhode Island v. Innis, 446 U.S. 291, 100 S.Ct. 1682, 64 L.Ed.2d 297 (1980). As such, Harnanan’s Fifth Amendment rights, as reflected in the Miranda warnings which had previously been provided to him, were not violated.
AFFIRMED.
PETERSON and PALMER, JJ„ concur.
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State v. Edenfield, 27 So. 3d 222 (Fla. 2d DCA 2010)…know what kind of trouble you are in” while defendant was seated in police cafeteria because the officer’s statement referred to the underlying crime for which the defendant was in custody and invited a response about that crime); Harnanan v. State, 780 So. 2d 183 (Fla. 5th DCA 2001) (holding that defendant was not subjected to custodial interrogation where he initiated conversation with police officer thereby waiving his Fifth Amendment rights). See generally State v. Hunt, 14 So. 3d 1035, 1038-39 (Fla. 2d D…
Authorities Cited
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981)
- Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980)
- Oregon v. Bradshaw, 462 U.S. 1039 (U.S. 1983)
- Minnick v. Mississippi, 498 U.S. 146 (U.S. 1990)