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State v. Boyd

Superior Court of Delaware

June 25, 2019

STATE OF DELAWARE
v.
RYAN T. BOYD, Defendant.

          Submitted: June 18, 2019

         Upon Defendant's Motion to Suppress GRANTED IN PART, DENIED IN PART

          Matthew C. Bloom, Esq., Department of Justice, Wilmington, Delaware, Attorney for the State

          Joe Hurley, Esq., Attorney for Defendant

          MEMORANDUM OPINION

          Hon. Mary M. Johnston, Judge.

         FACTUAL AND PROCEDURAL CONTEXT

         On May 8, 2018, after receiving a tip from an informant, law-enforcement officers visited the home of Defendant, Ryan T. Boyd. The informant alerted the officers to pipe bombs contained within Defendant's garage. Defendant's mother gave the officers consent to search the home, including the garage, where Defendant spent a lot of his time. The officers found three pipe bombs inside of a cooler bag on the garage floor.

         Upon discovering the pipe bombs, a detective conducted an informal interview of Defendant on scene. Defendant denied having any knowledge about the pipe bombs.

         On May 16, 2018, the State Fire Marshals brought Defendant in for a formal interview. Again, Defendant denied having any knowledge about the pipe bombs.

         On June 13, 2018, Defendant agreed to take a polygraph examination, which was followed by another interview.[1] It was revealed to Defendant that he did not perform well on the polygraph examination. Defendant stated that he was not happy with the results of the examination because he thought the results would exonerate him. During the subsequent two-hour interview, Defendant vacillated between denials, inculpatory statements, and recanting. After the interview, Defendant reportedly told his mother that he "told them the bull**** they wanted to hear."

         On June 28, 2018, Defendant returned to the Fire Marshal's office to make a statement. Accompanied by counsel, Defendant recanted the inculpatory statements made during the June 13 interview. Defendant has moved to suppress the statements given during the interviews.

         STANDARD FOR A MOTION TO SUPPRESS

         The Due Process Clause of the Fourteenth Amendment requires that a defendant's statement to law-enforcement be voluntary to be admissible against him at trial.[2] The State must prove voluntariness by the preponderance of the evidence.[3]

         ANALYSIS

         Voluntary or Involuntary Statement

         Whether a statement was given voluntarily is a question of fact based on the totality of the circumstances.[4] The Court must determine whether the investigators' conduct overbore the defendant's will to resist, and elicited a statement that was not the product of a rational intellect and free will.[5] The Court must consider "the specific tactics utilized by the police in eliciting the admissions, the details of the interrogation, and the characteristics of the defendant."[6] "In determining whether a defendant's will was overborne in a particular case, the Court has assessed the totality of all the surrounding circumstances-both the characteristics of the accused and the details of the interrogation."[7] Factors the Court can consider are:

the youth of the accused;
any lack of education or low ...

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