Commonwealth v. Rawls
| Decision Date | 17 August 2021 |
| Docket Number | No. 49 MAP 2020,49 MAP 2020 |
| Citation | 256 A.3d 1226 |
| Parties | COMMONWEALTH of Pennsylvania, Appellee v. Jordan Adonis RAWLS, Appellant |
| Court | Pennsylvania Supreme Court |
Michael F. J. Piecuch, Esq., Snyder County District Attorney's Office, Raymond Jay Tonkin, Esq., Pike County District Attorney's Office, for Pennsylvania District Attorneys Association, Amici Curiae.
Jules Epstein, Esq., Philadelphia, Edward J. Rymsza, Esq., Williamsport, Miele & Rymsza, P.C., for Appellant.
Ryan Coffman Gardner, Esq., Martin Lewis Wade, Esq., Lycoming County District Attorney's Office, for Appellee.
OPINION
This appeal concerns whether law enforcement agents violated the Sixth Amendment to the United States Constitution when, although issuing Miranda warnings to an arrestee during an interrogation, they failed to specifically apprise him that criminal charges already had been filed against him.
In October 2016, Appellant and Joseph Coleman perpetrated a home-invasion robbery in Williamsport, during which Kristine Kibler and her son, Shane Wright, were shot and killed. An accomplice, Casey Wilson, served in the role of a getaway driver.
Police investigated and garnered evidence giving rise to probable cause to believe that Appellant participated in the crimes, and a complaint charging him with two counts of criminal homicide and related offenses was filed. Shortly thereafter -- after learning that his picture was circulating in the media in association with the killings -- Appellant voluntarily presented himself at a police station to address what he initially depicted to the agents as the "crazy nonsense" he had heard. Transcript of Audio/Video Recording dated Nov. 11, 2016, in Commonwealth v. Rawls , No. CR-89-2017 (C.P. Lycoming) [hereinafter, "A/V Recording"], at 11. Appellant was immediately placed under arrest.
While shackled, Appellant was interrogated by agents for a period of five-and-one-half hours. At the outset, the lead investigator related to Appellant his rights under Miranda v. Arizona , 384 U.S. 436, 86 S. Ct. 1602, 16 L.Ed.2d 694 (1966). Among other things, he was told of his entitlement to be represented by an attorney during questioning and warned that anything that he said could and would be used against him in a court of law. See A/V Recording at 5. Appellant orally waived his rights and signed a written waiver form. He was also specifically admonished that: he was under arrest; he wasn't free to leave; the agents were investigating the criminal homicides that had appeared in the news; and they had probable cause to obtain a warrant for his arrest. See id. at 7. The agents, however, did not specifically advise Appellant that charges already had been lodged against him.
During the interrogation, Appellant initially denied knowing Coleman or Wilson and pervasively lied about his whereabouts before, at, and after the time of the home invasion. The agents repeatedly confronted him with contrary evidence, including video-surveillance footage showing the three co-perpetrators together in various locations, as well as phone records documenting extensive contacts, in relevant time frames. Ultimately, Appellant admitted that he was present at the crime scene when the robbery and homicides were committed, but he professed to having been unarmed, claiming to have served "basically like ... the lookout." Id. at 236.1
Appellant filed a pretrial motion seeking to suppress evidence of the interview. In one line of argumentation, he contended that, in the totality of the circumstances, his incriminatory statements were the product of inappropriate police tactics entailing deception, manipulation, and psychological coercion, thus invalidating his Miranda waiver per the Fifth Amendment. See Brief in Support of Omnibus Motion dated June 1, 2018, in Commonwealth v. Rawls , No. CR-89-2017 (C.P. Lycoming), at 8-9, 14-23. See generally Dickerson v. U.S. , 530 U.S. 428, 433-34, 120 S. Ct. 2326, 2330-31, 147 L.Ed.2d 405 (2000) ().
In the second line of his presentation, which gives rise to the legal question now before this Court, Appellant asserted that the agents violated his Sixth Amendment rights when they failed to inform him that criminal charges already had been filed against him. It was his position that, without such information, the waiver of his rights could not be deemed to have been knowing and intelligent. See generally Montejo v. Louisiana , 556 U.S. 778, 786, 129 S. Ct. 2079, 2085, 173 L.Ed.2d 955 (2009) ().2
After conducting a hearing, the suppression court found that Appellant had rendered a valid waiver of his right to counsel after receiving appropriate Miranda warnings.3 Regarding the totality assessment, the court found nothing to indicate that he was incapable of understanding the rights explained to him and no evidence that the agents threatened, tricked, or cajoled him. See Commonwealth v. Rawls , CR-89-2017, slip op. at 5-6, 8-9 (C.P. Lycoming Aug. 13, 2018).
As to the Sixth Amendment right to counsel, the court explained that, under the prevailing jurisprudence of the Supreme Court of the United States, when an accused voluntarily waives his Miranda rights, he also waives his Sixth Amendment right to counsel. See id. at 5-6 (citing, inter alia , Patterson v. Illinois , 487 U.S. 285, 293-94, 108 S. Ct. 2389, 2395-96, 101 L.Ed.2d 261 (1988) ); accord Commonwealth v. Woodard , 634 Pa. 162, 195-97, 129 A.3d 480, 500-01 (2015) (). Regarding the present circumstances, the court reasoned:
[Appellant] was admittedly aware that the incident [for] which he was wanted for questioning in connection to was the shooting death of two people. [Appellant] arguably understood the gravity of his arrest due to this knowledge. Further, [Appellant] was informed of the rights afforded to him and the consequences of abandoning such rights but chose to waive them regardless.
At trial, the Commonwealth presented testimony from Wilson, pursuant to a plea agreement, describing in detail his own involvement in the events, as well as that of Appellant and Coleman, and depicting Appellant as the shooter.4 Other corroborative testimony and evidence was admitted, and an audio-visual recording of Appellant's incriminatory interview with the agents was played for the jurors. Appellant was found guilty of first- and second-degree murder relative to the two victims, respectively, as well as other crimes, and he was sentenced to life in prison.
On appeal, the Superior Court adopted the suppression court's opinion, and we allowed this appeal, limited to the following issue as framed by Appellant:
Whether police, to protect a person's sixth amendment rights, must do more than administer Miranda warnings when the person is subject to police custodial interrogation and police deliberately fail to disclose that criminal charges have already been filed?
Commonwealth v. Rawls , ––– Pa. ––––, 237 A.3d 976 (2020) (per curiam ).5 In his presentation to this Court, Appellant relies substantially on Patterson v. Illinois to vindicate his position that disclosure of the filing of criminal charges is essential. Like the suppression and intermediate courts, however, the Commonwealth takes the view that Patterson militates strongly to the contrary.
In the divided opinion in Patterson , a majority of the Supreme Court of the United States rejected the argument that -- because the defendant's Sixth Amendment right to counsel had attached prior to the time that he was questioned by police officers -- his uncounseled confession couldn't be knowing and intelligent, and therefore, it should be suppressed. In this regard, the majority determined that the issuance of Miranda warnings made the defendant sufficiently aware, in "sum and substance," of his right to have an attorney present during questioning and the possible consequences of foregoing this entitlement. Patterson , 487 U.S. at 292-93, 108 S. Ct. at 2395.
In the course of the decision, the majority recognized the distinction between the rights to counsel under the Fifth and Sixth Amendments. See generally Montejo , 556 U.S. at 786-87, 129 S. Ct. at 2085 (). But, according to the Patterson majority, the Supreme Court has defined the scope of the right to counsel "by a pragmatic assessment" of counsel's usefulness and the danger presented to a defendant choosing to proceed uncounseled. Patterson , 487 U.S. at 298, 108 S. Ct. at 2398. In this respect, the Patterson majority viewed Fifth and Sixth Amendment entitlements -- relative to post-indictment interrogation -- as substantially overlapping.
Thus, the majority opined that warnings that are sufficient for purposes of the Fifth Amendment decision in Miranda will also generally suffice for Sixth Amendment purposes. See id. Along these lines, the majority explained:
The State's decision to take an additional step and commence formal adversarial proceedings against the accused does not substantially increase or decrease the value of counsel to the accused at questioning, or expand the limited purpose that an attorney serves when the accused is questioned by authorities. With respect to this inquiry, we do not discern a substantial difference between the usefulness of a lawyer to a suspect during custodial interrogation, and his value to an accused at...
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