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New Hampshire Supreme Court: Police Violated Miranda in Obtaining First Statement, and State Failed to Prove Second Statement Was Voluntary
by Douglas Ankney
The Supreme Court of New Hampshire affirmed a superior court’s decision suppressing the initial incriminating statements made by Dominic Carrier because police violated the protections of Miranda v. Arizona, 384 U.S. 436 (1966). The Court also affirmed the suppression of additional statements because the …
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More from this issue:
- A Nation on the Brink, by Christopher Zoukis
- Office of Homeland Security Circumventing Warrant Requirement by Buying Cellphone Location Data from Marketing Firm, by Anthony Accurso
- From the Editor, by Richard Resch
- Using Location Surveillance to Fight COVID-19 May Chill Free Speech and Association, by David Reutter
- This Is Not a Revolution. It’s a Blueprint for Locking Down the Nation, by John W. Whitehead
- Fourth Circuit Expands Savings Clause of § 2255(e) to Include Later Retroactivity of New Rule, by Dale Chappell
- Seventh Circuit: Defendant’s Statement Given to Pretrial Services Can’t Be Admitted to Impeach Witness at Trial, by Douglas Ankney
- California Court of Appeal Explains Procedural Requirements for Vacating Felony-Murder Conviction Via Section 1170.95 Petition, by Douglas Ankney
- Police Violence Detrimental to Public Health, by Douglas Ankney
- Congressmen File Amicus Brief Stressing Congressional Intent That First Step Act’s New Drug Laws Apply at Resentencing, by Dale Chappell
- Indiana Supreme Court: Removal of Police’s GPS Tracker on Suspect’s Vehicle Not Probable Cause of Theft, Suppression of Evidence, by Anthony Accurso
- New Hampshire Supreme Court: Police Violated Miranda in Obtaining First Statement, and State Failed to Prove Second Statement Was Voluntary, by Douglas Ankney
- 5-Year Study Shows Police Stop Black Drivers Less Often at Night When ‘Veil of Darkness’ Obscures Race, by Douglas Ankney
- Declassified Court Ruling Details FBI Abuses of Mass Surveillance Data, by Anthony Accurso
- Second Circuit: Three Important Rulings Under First Step Act, by Dale Chappell
- Marijuana Possession in Virginia Remains Illegal But Is Decriminalized, by Douglas Ankney
- Eleventh Circuit Holds Hobbs Act Robbery Doesn’t Trigger Career Offender Enhancement, by Dale Chappell
- Biden Accuser Accused of Inflating Credentials to Qualify as Expert Witness, Calling Convictions into Question, by Derek Gilna
- COVID-19 Creates Opportunity for Big Brother in the Sky, by Michael Fortino, Ph.D
- Perjurous New York City Cop Sentenced to a Single Day in Jail, by Edward Lyon
- Fourth Circuit: Standalone Rehaif Error Requires Automatic Vacatur of Guilty Plea, by David Reutter
- Nebraska Supreme Court: Multiple Theft Charges for Stealing Items Belonging to Several People at Same Time and Place Violates Double Jeopardy, by Dale Chappell
- Is the Death Penalty Slowly Dying Across the Nation?, by Chad Marks
- Joint State-Federal Task Forces Practice Rogue Justice Under Protection of Qualified Immunity, by Michael Fortino, Ph.D
- Colorado Supreme Court: Requiring Defense to Disclose Exhibits to Prosecution Before Trial Violates Due Process Rights, by Dale Chappell
- Iowa Supreme Court Orders Dismissal of Charges that State Brought in Breach of Plea Agreement, by Douglas Ankney
- Carpenter Slowly Remaking Fourth Amendment Case Law, by Anthony Accurso
- Justice Office Awards $145 Million in Forensic Science Grants, by Anthony Accurso
- Aggressive NYPD Police Tactics Spreading COVID-19, by Michael Fortino, Ph.D
- California Federal Court Rejects Plea Agreement’s Waiver of Compassionate Release Provision, by David Reutter
- COVID-19 Causing Some Pretrial Detainees to Spend More Time in Jail, by Douglas Ankney
- California Supreme Court Announces Sentencing Law Changes Apply Until Revocation Sentence Becomes Final, by Anthony Accurso
- NY Court of Appeals: Right to Review Suppression Decision When Decision Relates Solely to a Count Satisfied by Plea but Isn’t Count to Which Defendant Pled, by Douglas Ankney
- Report: Cops Ill-Equipped to Handle Mental Illness Crisis in Hospitals, by Edward Lyon
- Plenty of Practice Prevents Poor Police Performance, by Edward Lyon
- Fifth Circuit Clarifies How ‘Pronouncement Requirement’ Applies to Supervision Conditions, by Douglas Ankney
- First Circuit: Sentence Imposed Under 21 U.S.C. § 841(a)(1), (b)(1)(c) Is ‘Covered Offense’ Under § 404 of First Step Act, by Douglas Ankney
- Sixth Circuit: Courts May Consider Good Prison Conduct in Sentence Reduction Under First Step Act, by Dale Chappell
- Minnesota Supreme Court: Hotel Guests Have Reasonable Expectation of Privacy in Registry Information, by Douglas Ankney
- DNA Database of NYC’s Chief Medical Examiner Plagued with Errors, by Douglas Ankney
- Pennsylvania Supreme Court: Expired Vehicle Registration Isn’t ‘Breach of the Peace’ Justifying Traffic Stop, by Douglas Ankney
- South Carolina Supreme Court Rejects U.S. Supreme Court’s Shifting of Burden to Defendant to Prove Absence of Exigent Circumstances in DUI Cases, by Douglas Ankney
- Report: Risk Assessment Tools not Effective, Especially When not Used, by Kevin Bliss
- Sixth Circuit: District Court’s Refusal to Reduce Crack Sentence Under First Step Act Requires Justification, by Dale Chappell
- Florida Supreme Court Abandons Circumstantial Evidence Review Standard, by David Reutter
- Courts Oppose Prosecutors’ Attempts to Right Past Wrongs, by Douglas Ankney
- No Trust Between Police and Communities They Patrol, by Kevin Bliss
- North Carolina Supreme Court: Giving Finger to Police Not Disorderly Conduct Justifying Traffic Stop, by Dale Chappell
- COVID-19 May Ring in a New Era of High-Tech Private Policing, by Michael Fortino, Ph.D
- New Technique Separates Mixed DNA Evidence to Tell Suspects from Victims, by Dale Chappell
- Feds Ramp up Purchase of Riot Gear in Wake of COVID-19 Pandemic, by Douglas Ankney
- Sixth Circuit Vacates Firearms Possession Conviction; Government Showed Jury Unauthenticated Prejudicial Facebook Video Not Admitted as Evidence, by Matthew Clarke
- Army Veteran Serving Life Without Parole for Taking $9, by Douglas Ankney
- News in Brief
More from Douglas Ankney:
- The Dramatic Increase in the Elderly Prison Population Is Fiscally and Morally Irresponsible, Oct. 1, 2026
- Second Circuit Affirms Denial of Qualified Immunity but Clarifies that 14th Amendment ‘Objective Reasonableness’ Is Standard of Review for Pretrial Detainee’s Claim of Sexual Abuse, Oct. 1, 2026
- California Supreme Court Announces Totality-of-Circumstances Framework Focused on Defendant’s Subjective Understanding Under § 1473.7(a)(1), Holding Immigration Consequences Advisement Is Relevant but Not Dispositive, Oct. 1, 2026
- Idaho Supreme Court Holds Conflicting Affidavits About Plea Acceptance Require Evidentiary Hearing on Ineffective-Assistance Claim, Oct. 1, 2026
- Tenth Circuit Vacates Award of Costs to Prison Officials, Revives Prisoner’s Claim Alleging Denial of Access to Functioning Toilets and Exposure to Other Prisoners’ Feces, Oct. 1, 2026
- Second Circuit Vacates Above-Guidelines Firearm-Trafficking Sentence Based on Failure to Assist Law Enforcement and Unexplained Reliance on Factors Already Included in Guidelines Range, Sept. 1, 2026
- Ninth Circuit Reverses Convictions, Holding Requirement That Defendant Testify Before Displaying Hand Tattoos Violates Fifth Amendment, Sept. 1, 2026
- Ohio Supreme Court Announces Postconviction DNA-Testing Orders Need Only Identify Statutory Reason to Satisfy R.C. 2953.73(D) “Reasons” Requirement, Sept. 1, 2026
- Federal Court Upholds Consultants’ Finding that Oklahoma Is Not Honoring Its Consent Decree to Provide Mental Health Treatment, Sept. 1, 2026
- Idaho Legislature Moves to Hide Execution Protocol from Judicial Scrutiny, Sept. 1, 2026
More from these topics:
- Alaska Supreme Court Announces “Stop and Clarify” Rule Under Article I, Sections 9 and 11 of Alaska Constitution, Holding Officers Must Cease Questioning and Clarify Ambiguous Post-Waiver Request for Counsel, Sept. 1, 2026. Constitution, state, After Request for Counsel, Police Interrogations, Custodial Interrogations, Invocation of Rights.
- Chronotype Mismatch as an Emerging Vulnerability Factor in Custodial Confessions, May 1, 2026. Confessions - Admissibility, Evidence - Integrity/Reliability of, Custodial Interrogations, Interrogation, Voluntary Nature/Voluntariness.
- Hawaii Supreme Court Announces State Constitution Requires Law Enforcement to Record All Custodial Interrogations, Overruling Three-Decade-Old Precedent and Recognizing New Due Process Right, March 1, 2026. Constitution, state, Confrontation Clause/Rights, Self-Incrimination Clause, Custodial Interrogations, Video Recordings.
- Washington Supreme Court Announces Race and Ethnicity Are Relevant Factors Courts May Consider When Applying the Totality of the Circumstances Test for Determining Whether Suspect Is “In Custody” for Miranda Purposes, Feb. 1, 2026. Community Caretaking Exception/Doctrine, Traffic Stops, Self-Incrimination Clause, Custodial Interrogations, In Custody.
- California Court of Appeal Holds Perkins Operation Violated Miranda Where Known Law Enforcement Officer’s “Stimulation” Tactics Amounted to Custodial Interrogation After Suspect Invoked Right to Counsel, Feb. 1, 2026. Confessions - Admissibility, After Request for Counsel, Police Interrogations, Custodial Interrogations, Invocation of Rights.
- Washington Supreme Court Holds Courts Must Meaningfully Consider Youth When Assessing Miranda Waiver and Clarifies That Res Gestae Exception Requires Temporal Proximity to Charged Crime, Feb. 1, 2026. Police Interrogations, Juvenile Offenses/Offenders, Bad Acts Evidence, Custodial Interrogations, Denial of Due Process.
- Colorado Supreme Court Holds Defendant Was in ‘Custody’ for Miranda Purposes Because She Had Hands Bagged and Zip Tied, Commanded Not to Remove Them, and Questioned Alone in Interrogation Room With Door Closed, Feb. 15, 2025. Miranda, Custodial Interrogations.
- Eleventh Circuit Reverses District Court’s Grant of Habeas Relief, Notes It’s ‘Murky on When Putting Two Suspects in a Room Together Qualifies as Interrogation Under Miranda’, July 15, 2024. AEDPA, Miranda, Custodial Interrogations, Minors, Use of, Interrogation.
- Oregon Supreme Court Rules Police Questioning of Probationer in Probation Officer’s Secure Office Absent Miranda Warning Constitute ‘Compelling Circumstances’ and Suppresses Statements, June 15, 2024. Miranda, Custodial Interrogations, Interrogation, In Custody.
- DEA and Police Use Pretense of Consent Searches to Effectively Steal Cash From Airport Travelers, March 15, 2024. Racial Profiling, Consent, False Inducement, Police/Govt Misconduct.





