AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Child-Appellant was convicted by a jury for driving under the influence of intoxicating liquor, driving without a license, and failure to maintain a traffic lane. During the arrest, the Child was described as very intoxicated, having difficulty communicating, and eventually vomited and passed out. Despite these conditions, the Child was read her "mini-Miranda" rights and agreed to speak with the deputies. The Child's blood alcohol concentration (BAC) was recorded at .18 at the police substation.

Procedural History

• Appeal from the District Court of San Juan County, Dalene Marsh, District Judge.

Parties' Submissions

• State: Argued that the children’s court did not err in finding that the Child made a knowing, voluntary, and intelligent waiver of her Miranda rights, citing uncontroverted testimony that the Child indicated understanding of her rights and agreed to speak with deputies.
• Child-Appellant: Implicitly argued that her intoxication level at the time of waiving her Miranda rights compromised her ability to make a knowing, intelligent, and voluntary waiver.

Legal Issues

• Whether the State satisfied its burden to prove by a preponderance of the evidence that the Child knowingly and intelligently waived her Miranda rights despite her intoxication level.

Disposition

• The Court of Appeals reversed the district court’s decision not to suppress the statements made by the Child and remanded for a new trial.

Reasons

• The Court, with M. Monica Zamora, Timothy L. Garcia, and J. Miles Hanisee concurring, found that the State did not meet its burden to prove that the Child knowingly and intelligently waived her Miranda rights. The Court considered the Child's physical and mental condition at the time of being questioned, noting her high level of intoxication, difficulty in communicating, and subsequent actions such as vomiting and passing out. Despite the State's argument that the Child had verbally acknowledged her understanding of her rights, the Court held that the Child's extreme intoxication was inconsistent with a knowing and intelligent waiver of rights. The Court referenced previous case law indicating that voluntary intoxication is relevant to determining whether a waiver was knowing and intelligent and that extreme intoxication is inconsistent with such a waiver. The Court was not persuaded by the State's attempt to distinguish this case from precedent on the basis of the Child's BAC level or her improved demeanor at the police substation, emphasizing that the conditions under which the waiver was given did not support a finding of voluntary waiver.