People of Michigan v. Joshua Lamar-James Stewart

Summary

The Michigan Supreme Court held that the defendant’s statements during an early-morning police interrogation were involuntary under the totality of the circumstances. The Court found that the combined effects of defendant’s age, likely sleep deprivation, implied sentencing leniency, false claims about evidence, and the officers’ combative language overbore his free will. The constitutional error was not harmless beyond a reasonable doubt because the involuntary statements supplied the principal evidence connecting defendant to the robberies, so the Court reversed and remanded for a new trial.