Bobby v. Dixon

In Bobby v. Dixon (2011) U.S. 132 S.Ct. 26, the defendant and another murdered the victim by beating him and then burying him alive. (Dixon, supra, 132 S.Ct. at p. 27.) Dixon used the victim's information to obtain a state identification card in order to sell the victim's car. (Ibid.) The police had three encounters with Dixon. The second occurred when they arrested him for forging the victim's signature when cashing the check received for the sale of the victim's car. (Id. at p. 28.) The detectives interrogated Dixon for hours without providing Miranda warnings. Dixon admitted obtaining the identification card in the victim's name and signing the victim's name on the check; however, he claimed that he was ignorant of the victim's whereabouts. (Dixon, supra, at p. 28.) Even when the detectives told Dixon that his partner was providing more information on the victim's disappearance, Dixon continued to deny any knowledge. (Ibid.) Dixon was taken to a correctional facility, where he was booked on a forgery charge. (Ibid.) After obtaining the relevant information from Dixon's partner, the police transported Dixon back to the station from the facility. Dixon admitted hearing that the victim's body was found. After learning that his partner was not in custody, Dixon stated that he had talked to his attorney and wanted to tell the detectives what happened. After being read his Miranda rights and waiving them, Dixon confessed to murdering the victim. (Dixon, supra, 132 S.Ct. at p. 28.) At trial, Dixon's confession to forgery and murder were excluded. On appeal, the appellate court allowed the murder confession, and Dixon was convicted of murder, among other things. (Id. at pp. 28-29.) Dixon challenged his conviction, claiming his confession should not have been admitted. (Id. at p. 29.) When his appeal reached the United States Supreme Court, the justices distinguished the facts from those in Seibert and concluded there was "no two-step interrogation technique of the type . . . in Seibert . . . ." (Dixon, supra, at p. 31.) The court went on to state: "In Missouri v. Seibert (2004) 542 U.S. 600, the suspect's first, unwarned interrogation left 'little, if anything, of incriminating potential left unsaid,' making it 'unnatural' not to 'repeat at the second stage what had been said before.' . But in this case Dixon steadfastly maintained during his first, unwarned interrogation that he had 'nothing whatsoever' to do with the victim's disappearance. Thus, unlike in Seibert, there is no concern here that police gave Dixon Miranda warnings and then led him to repeat an earlier murder confession, because there was no earlier confession to repeat. Indeed, Dixon contradicted his prior unwarned statements when he confessed to the victim's murder. Nor is there any evidence that police used Dixon's earlier admission to forgery to induce him to waive his right to silence later: Dixon declared his desire to tell police what happened to the victim before the second interrogation session even began. As the Ohio Supreme Court reasonably concluded, there was simply 'no nexus' between Dixon's unwarned admission to forgery and his later, warned confession to murder. " (Id. at p. 31.)