State v. Culbreath

Summary

The court held that defense counsel waived the defendant’s federal Miranda claim by affirmatively stating that he had no objection to the admission of the interrogation recording and written statement, but did not knowingly waive the state constitutional claim because controlling law changed after trial. The court further held that the detective violated the state constitution by continuing interrogation after the defendant made an equivocal request for an attorney without adequately clarifying whether he wanted counsel. Because the improperly admitted statements were not harmless beyond a reasonable doubt as to the self-defense-based manslaughter conviction, that conviction was reversed for a new trial, while the remaining challenged convictions were affirmed.