State of Maine v. Julio Cesar Hernandez-Rodriguez

Summary

The court held that questions used to identify Hernandez-Rodriguez’s phone were not custodial interrogation, and that he knowingly, intelligently, and voluntarily waived his rights during the post-arrest interview despite limited English proficiency. It held, however, that an agent’s question asking whether a substance was cocaine was custodial interrogation conducted without a valid waiver, so the resulting answer should have been suppressed. Because Hernandez-Rodriguez entered a conditional plea and the court could not determine whether suppression of that answer affected his decision to plead guilty or proceed to trial, it vacated the conviction and remanded.