Feb. 18, 2014 – Stanley Bullock was in the hospital with stab wounds when police asked him to explain what happened. Recently, a state appeals court ruled that Bullock made statements voluntarily and they could be used in a murder trial against him.
Bullock’s girlfriend had been stabbed to death. Bullock claimed that masked intruders broke into their apartment while they were asleep and stabbed both of them.
Bullock had been in and out of consciousness before calling 9-1-1 the next day, he told two detectives. But other evidence suggested that Bullock may have been the killer. Namely, his DNA was on the murder weapon, and his wounds seemed self-inflicted.
The state charged Bullock for the murder of his girlfriend. He filed a motion to suppress the statements made to detectives at the hospital, but the trial court judge denied the motion. Bullock later pleaded guilty to first-degree reckless homicide before appealing.
Bullock argued that suppression was warranted because his statements were made while he was in pain from the stab wounds. Thus, he did not make them voluntarily.
The trial court, after hearing the recorded statements he made at the hospital, noted that police read Bullock his Miranda rights before questioning him, he did not ask for a lawyer, and the audio did not reveal that Bullock was experiencing a great deal of pain.
Bullock relied on a U.S. Supreme Court case in which the court ruled that police violated a defendant’s constitutional rights when they questioned him as a hospital patient. Likewise, Bullock said detectives pressured him while medicated and vulnerable.
But in State v. Bullock, 2013AP435-CR (Feb. 18, 2014), a three-judge panel for the District I Court of Appeals ruled that police did not violate Bullock’s rights.
“[W]hile Bullock did make moaning sounds due to his pain at the beginning of the hospital interview, there is no indication that the pain interfered with his ability to speak with law enforcement in these particular circumstances,” wrote Judge Patricia Curley.
“While Bullock makes much of the fact that he did not know what day it was when being questioned at the hospital, he does not dispute the trial court’s finding that he generally answered questions appropriately and in detail,” Curley explained.
The appeals panel reviewed other factors to conclude that his statements were made freely and not against his will, including his age and intelligence level. The panel also noted that prior run-ins with police made Bullock less vulnerable to police pressures.
Recorded police questioning did not reveal unconstitutional pressures, the panel noted, rejecting Bullock’s claim that interrogation by two detectives evidenced coercion.
“Bullock takes issue with the fact two detectives questioned him at the hospital, but that fact, without more, is not enough to evince coercion,” wrote Judge Curley, noting that police questioning is not coercive absent affirmative evidence of improper practices.
The appeals court also noted that Bullock’s reliance on Mincey v. Arizona, 437 U.S. 385 was misplaced. In that case, the hospitalized defendant’s condition was much worse and police questioned him for four hours after he asked for a lawyer to be present.