Miranda and the Nexus Between a Confession and a Coercive Interrogation

In Bobby v. Dixon:

Archie Dixon and Tim Hoffner murdered Chris Hammer in order to steal his car. Dixon and Hoffner beat Hammer, tied him up, and buried him alive, pushing the struggling Hammer down into his grave while they shoveled dirt on top of him. Dixon then used Hammer’s birth certificate and social security card to obtain a state identification card in Hammer’s name. After using that identification card to establish ownership of Hammer’s car, Dixon sold the vehicle for $2,800.

On November 4, Defendant Dixon went to the police station. A police detective Mirandized Dixon, at which point Dixon refused to speak without an attorney. The Defendant left the police station.

On November 9, suspicion focused even more on Dixon and he was arrested for forgery. He was not charged with murder, even though police did suspect him of the murder.

Police intentionally withheld Miranda warnings. They questioned him about the murder and the forgery. The defendant admitted to the forgery, but refused to confess to the murder.

Police tried to persuade Dixon over four hours to admit to the murder, telling him that they had his co-defendant in custody and whoever confessed first would get the better deal. Dixon refused to confess, and was arrested for the forgery and placed in custody.

He was taken to jail.

Four hours thereafter Dixon was returned to the police department, where he was re-interrogated. Dixon said that he had heard that that police had found the body, and asked whether his accomplice was in custody. Dixon said, I’ve spoken to my lawyer and I’d like to talk. Police provided him his Miranda warnings (on tape). Dixon confessed, which was later used at trial to convict him of murder.

He appealed, saying that the failure to read the Miranda Warnings early enough constituted a violation of his rights in Arizona v. Miranda.

The Supreme Court held that the confession was not coercive, and that there was not enough of a connection between the unwarned confession and the police suspicion and the requirement that Miranda Warnings be read.

Damon Chetson

Damon Chetson is a Board Certified Specialist in State and Federal Criminal Law. He represents people charged with serious and minor offenses in Raleigh, Wake County, and the Eastern District of North Carolina. Call (919) 352-9411.