People v. Thomas

8 N.E.3d 308 (2014)

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People v. Thomas

New York Court of Appeals
8 N.E.3d 308 (2014)

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Facts

Wilhelmina Hicks and Adrian Thomas (defendant) found their four-month-old son, Matthew, unresponsive. Matthew was rushed to the hospital and diagnosed with head injuries from blunt-force trauma. Matthew died of his injuries. Matthew’s treating physician believed Matthew had been murdered. After Matthew’s death, while Wilhelmina was still at the hospital, police brought Adrian in for questioning. Police questioned Adrian for two hours before Adrian expressed suicidal ideation and was involuntarily hospitalized for 15 hours in a psychiatric unit. After Adrian’s release, police resumed questioning for another seven and a half hours. Police knew that the treating physician suspected Matthew was murdered but did not inform Adrian of Matthew’s death. Police repeatedly assured Adrian that Matthew’s injuries were an accident, that Adrian would not be arrested if he told the truth, and that any information Adrian shared would be relayed to Matthew’s doctors and could help save Matthew’s life. Police also threatened to remove Wilhelmina from the hospital for questioning if Adrian refused to relate what happened, after which Adrian stated that he would “take the fall.” One of the officers suggested in detail that Adrian had thrown Matthew down onto a low-lying mattress and instructed Adrian to show police what had occurred. Adrian acted out what the officer had suggested. The state (plaintiff) charged Adrian with murder. The trial court denied Adrian’s motion to suppress a video recording of his interrogation. Adrian was convicted and appealed.

Rule of Law

Issue

Holding and Reasoning (Lippman, C.J.)

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