State v. Sampson
In State v. Sampson, 808 P.2d 1100 (Utah Ct. App. 1990), the Utah Court of Appeals reversed Sampson's conviction for second-degree murder, holding that inculpatory statements he made concerning the death of his daughter were the result of a custodial interrogation and were made without the benefit of the Miranda advisements.
Sampson had initially claimed that his daughter had been kidnapped, but the police informed him that they did not believe his story and asked him to come to the police headquarters, the following morning, to take a polygraph exam. He agreed to do so. Id. at 1101.
The next morning, the polygraph examiner explained the process of and procedures for administering the test and gave Sampson the Miranda advisements, but the examiner did not obtain a valid waiver from Sampson of his right to counsel. Id.
After administering the test, the polygraph examiner informed Sampson that the answer he gave to one question (which had been repeated, as part of a battery of questions, four times), that is, whether he knew where his daughter was hidden, appeared to be false. Id. 1102.
Although continuing to deny that he knew anything, he suggested that his wife might. Id.
Thereafter, the polygraph examiner informed another officer about the results, stating that he believed that Sampson was being untruthful. He further advised the officer that Sampson had been given the Miranda advisements. Id.
That officer then took over the questioning of Sampson, but without giving him the Miranda advisements, relying instead on the polygraph examiner's assurance that he had already given Sampson those advisements. Id.
During the ensuing interrogation, he informed Sampson that there were inconsistencies in his story and that he did not believe that Sampson was telling the truth. Id.
Ultimately, Sampson "stated his daughter was dead and that he could show the police where she was located." Id.
On appeal, the Utah intermediate appellate court reversed the trial court, holding that that court had erred when it concluded that Sampson was not in custody when he made his inculpatory statements.
The Utah appellate court declared that "two factors which conclusively tipped the scale" in favor of custody were "the focus of the investigation" and "the form of the interrogation." Id. at 1105.