State v. Garrison

Citations

• 213 Conn. App. 786

Syllabus

The defendant, who had been convicted, after a trial to the court, of the crime of assault in the first degree, appealed to this court, claiming that the trial court had improperly denied his motion to suppress certain statements he made to police officers while he was in a hospital examin- ing room where he was attached to an intravenous line. The defendant claimed that the statements were inadmissible because they were the product of custodial interrogation, and the police had not advised him of his rights pursuant to Miranda v. Arizona (384 U.S. 436). The state disagreed and claimed that, even if the police were required to advise the defendant of his rights pursuant to Miranda, the admission of his statements at trial was harmless beyond a reasonable doubt. The defen- dant had visited P and another man at their apartment, where the men consumed beer and whiskey and socialized. The men became highly intoxicated. An argument ensued, and P punched the defendant in the face. The defendant thereafter attacked P from behind and stabbed him six times with a knife. The defendant then walked to a nearby hospital. He was brought to the examining room, where he remained that evening and into the early morning for about four and one-half hours. The attending physician did not permit him to be discharged until he regained sobriety. At various times, five different police officers conducted multi- ple rounds of questioning of the defendant in his hospital room, during which he made inculpatory statements. One of the officers also tran- scribed the defendant's version of the events at issue, placed him under oath, instructed him to sign the written statement and then left the hospital room. The officer returned later and informed the defendant that he was free to leave the hospital but only if the medical staff allowed him to do so. None of the officers ever advised the defendant of his rights pursuant to Miranda or told him that he was under arrest or that he could terminate