Recent Development: Williams v. State: A Confession is Voluntary Unless the Defendant Unambiguously Invokes His Constitutional Right to Remain Silent or the Confession is Obtained Through Coercion or Inducement

Authors

Pascale CadelienFollow

Abstract

The Court of Appeals of Maryland held that “I don’t want to say nothing. I don’t know,” is an ambiguous invocation of the right to remain silent. Williams v. State, 445 Md. 452, 455, 128 A.3d 30, 32 (2015). The court reasoned that the defendant’s addition of “I don’t know” to his initial assertion “I don’t want to say nothing” created uncertainty about whether he intended to invoke his right to remain silent. Id. at 477, A.3d at 44. This allowed a reasonable officer to interpret his statement as an “ambiguous request to remain silent.” Id. Furthermore, the officers’ implication that the defendant should confess to a “robbery gone bad,” instead of premeditated murder, did not induce his confession. Id. at 477-483, A.3d at 45-48. Accordingly, the defendant’s confession was voluntary.

Recommended Citation

Cadelien, Pascale (2016) "Recent Development: Williams v. State: A Confession is Voluntary Unless the Defendant Unambiguously Invokes His Constitutional Right to Remain Silent or the Confession is Obtained Through Coercion or Inducement," University of Baltimore Law Forum: Vol. 46: No. 2, Article 12.
Available at: https://scholarworks.law.ubalt.edu/lf/vol46/iss2/12