Friday, November 15, 2013

Caputo v. Nelson case brief

Caputo v. Nelson case brief summary
455 F.3d 45 (2006)

Petitioner inmate appealed from the United States District Court for the District of Massachusetts, which denied his petition for a writ of habeas corpus. After the inmate appealed, the district court issued a certificate of appealability, limiting the appeal to the inmate's claim that his privilege against self-incrimination was violated when his statements were introduced at trial.

The inmate contended that his first-degree murder conviction was based on evidence obtained in violation of the Fifth Amendment privilege against self-incrimination. He asserted that a police officer's use of the inmate's telephone, in his presence, to relay information as to officers' discoveries at the inmate's home was the functional equivalent of interrogation because it was reasonably likely to elicit an incriminating response from the inmate after he had claimed his right to remain silent. Citing Miranda, the inmate maintained that the story he blurted out upon hearing the officer's telephone conversation should have been suppressed as the product of that allegedly unlawful interrogation.

  • Reviewing pursuant to the Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-132, 110 Stat. 1214 (1996), the court was not persuaded. 
  • The court agreed with the state court that inmate was not subjected to the functional equivalent of interrogation, and his Fifth Amendment right against compelled self-incrimination was not violated, when the police officer made the telephone call. 
  • As a result, the inmate's later statements could not have been fruit of the poisonous tree.

The court affirmed the judgment of the district court, denying the inmate's petition for a writ of habeas corpus.

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