On Point: b. Confessions/self-incrim.

seventh circuit decision

Habeas Review – Confessions – Voluntariness 

Given the deferential nature of habeas review, the state court reasonably determined that a 16-year-old’s confession after 55 hours of interrogation was voluntary:

Particularly in light of the highly deferential standard due to the state court, we have no reason to doubt that it took into account all of the relevant facts, highlighting only those that seemed especially pertinent to the voluntariness of the confession.

seventh circuit court of appeals decision

Habeas Review – Miranda-Edwards 

Coleman’s argument that his confession violated Edwards v. Arizona, 451 U.S. 477 (1981) (interrogation must cease immediately if suspect requests counsel) was rejected by the state court based upon a determination that he did not in fact assert his to counsel. Denial of relief is affirmed:

Coleman admits but downplays the crucial difference here: In Edwards,

7th Cir. decision; Order denying rehearing and amending opinion, 10/10/15

Habeas – Voluntary Statement – Juvenile

State court determination that juvenile’s custodial statement to police was voluntary wasn’t objectively unreasonable., notwithstanding his age (15), borderline intellectual functioning and lack of criminal background. “(I)t is the totality of the circumstances underlying a juvenile confession, rather than the presence or absence of a single circumstance, that determines whether or not the confession should be deemed voluntary.”

7th circuit court of appeals decision

Habeas – Miranda Waiver

Viewed through the deferential lens of 2254 habeas review, a state court finding that the severely mentally impaired Collins knowingly and intelligently waived his Miranda rights an incriminatory statement was not unreasonable.

Collins had a Wechsler-scale IQ in the low- to mid-60s, exacerbated by a brain aneurysm that damaged his frontal lobes and left him with a language disorder.