Walker v. State

In Walker v. State, 707 So. 2d 300 (Fla. 1997), the Court considered a defendant's claim that the police used a number of coercive tactics to obtain a confession. The Court described one of the tactics as "knowing that Walker was a deacon in his church, police exploited his religious beliefs when they told him that God would not believe his 'abduction' story." The Court affirmed the trial court's denial of the motion to suppress, finding that the record supported the trial court's conclusion that the confession was given freely and voluntarily. The Court rejected the defendant's argument that the trial court erred by denying his motion to suppress expert testimony concerning DNA evidence that was recovered from a cigarette filter found in the victim's car because it "was not relevant to any fact at issue in the case" since the test results were "not probative, by themselves," of the defendant's or his brother's presence in the victim's car. 707 So. 2d at 313. The DNA expert testified that the DNA on the filter was "shared by the defendant, his brother, and 12.2 percent of the African-American population, 6 percent of the Caucasian population, and 4.8 percent of the Hispanic population." Id. The Court held that the defendant's concerns went "to the weight of the DNA evidence--which he had an opportunity to argue was low--and not to its admissibility." Id. The Court upheld the trial court's denial of the defendant's motion to suppress. In Walker, detectives had questioned the defendant for six hours, provided drinks "upon request," and allowed him to use the restroom. Id. at 311. The detectives had also reminded the defendant that the death penalty was a potential punishment for murder, but did not threaten the defendant with the electric chair or promise him anything other than informing the prosecutor that the defendant had cooperated. Id. The trial court described the tactics used by interrogating detectives as techniques that "everyone knows about" and "have not been disapproved by the law in any way." Id. On direct appeal, the Court held that the interrogation "simply could not be characterized as so coercive as to render the confession involuntary." Id. The Courtheld that it was improper for the State to interject the probability of recurring violent acts by the defendant in the future, noting that such a fact is "not a proper aggravating circumstance." Id. at 314. Although the Court found that these comments were harmless, the Court reiterated its holding in Miller that it is improper to "attach aggravating labels to factors that actually should militate in favor of a lesser penalty--like . . . the defendant's mental impairment." Id.