Sunday, November 17, 2013

State v. Tuttle case brief

State v. Tuttle case brief summary
650 N.W.2d 20 (2002)

Defendant was convicted in the Minnehaha County Circuit Court (South Dakota) of aggravated assault. Defendant appealed.

Defendant argued, inter alia, that the trial court erred by denying his motion to suppress his confession to police because the confession was not voluntary.


  • The supreme court agreed. 
  • The following weighed in favor of adjudging defendant's statement voluntary. 
  • There was no evidence that he lacked sufficient education or intelligence to understand the alternatives open to him, the length of his detention was less than an hour, the questioning, though somewhat repetitious, was not prolonged through several sessions, he did not suffer physical punishment or deprivation. 
  • However, because he was in custody and interrogated in a holding cell at 2:30 a.m., he was under the influence of alcohol, he was 18 years old at the time, he was deceived about statements of eyewitnesses, and he was subjected to an implied threat of more serious consequences if he refused to admit guilt, the scale tilted toward holding the confession involuntary. 
  • Therefore, the trial court erred by denying defendant's motion to suppress his confession.

The judgment was reversed and the case was remanded.

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