On Point blog, page 1 of 1
Court of appeals again blurs harmless error test
State v. Julius Alfonso Coleman, 2013AP2100-CR, 3/21/2017, District 1 (not recommended for publication); case activity (including briefs)
Julius Coleman was set up by a confidential informant to participate in an armed robbery of a nonexistent drug dealer named “Poncho.” He challenges the admission of various statements at trial on the ground that they were taken in violation of Miranda. The court of appeals concludes that any error in their admission was harmless beyond a reasonable doubt, but along the way (and not for the first time) seems to confuse the test for harmless error with that for sufficiency of the evidence.
Confessions: “Sew-Up” – Scrupulously Honored Silence – Voluntariness
State v. Devon L. Bean, 2011 WI App 129 (recommended for publication); for Bean: Scott D. Obernberger; case activity
Sew-up Confession
The fourth interrogation of Bean within a 60-hour period following his arrest did not, under the particular facts, amount to an impermissible “sew-up” confession.
General principles. The question, in brief, is whether the time between arrest and formal charge was “inordinate.”