Dye v. Commonwealth

After police discovered the body of a nine-year-old girl in a thicket near her home, they executed a search warrant at the girl’s home and brought her parents and 17-year-old brother, Garrett Thomas Dye (defendant) in for questioning. At the time, Dye’s father told police not to question Dye until Dye could retain a lawyer. Police did not question Dye that day, but the following day, police arrested Dye for murder, read his Miranda rights, and transported him to the local courthouse, where two pairs of two officers questioned Dye for about two hours. Dye made no incriminating statements for the first 80 minutes of the tape-recorded interview. Police repeatedly lied to Dye that he was facing the death penalty and would spend decades in solitary confinement awaiting his death. However, police knew that as a minor, Dye could not be death-penalty eligible. Police also repeatedly told Dye he would be raped every day in prison because he was young and a child-murderer. Dye began to cry during a break, and he told police he was scared. About 80 minutes into the interrogation, Dye said, “I just don’t want to say anything until my lawyers get here.” An officer warned Dye that he would miss his chance to talk with police if he waited to speak with his attorney because the officer did not like to speak with attorneys. Moments afterward, Dye began confessing to murdering his sister. Based on Dye’s confession, police obtained a second search warrant and recovered additional incriminating physical evidence from Dye’s home. Dye moved to suppress his confession before trial, but the district court denied the motion. Dye pleaded guilty to murder and other offenses and was sentenced to 50 years of incarceration. Dye appealed.