Background
John Harold Sanders was arrested without a warrant in January 2013 after bringing his three-month-old daughter to a hospital with injuries that a physician suspected were caused by abuse. His daughter died that evening, and an autopsy attributed her death to traumatic brain injury and classified it as a homicide.
After Sanders had been detained for at least 64 hours without a judicial determination of probable cause, he waived his Miranda rights and spoke with a detective. Sanders initially denied harming his daughter but later offered varying explanations, including that he shook her when she would not stop crying. A magistrate found probable cause later that day. Sanders was convicted of felony murder and first-degree child abuse, but he subsequently obtained a new trial based on trial counsel’s failure to seek assistance from a medical expert.
Before the retrial, the trial court ruled that Sanders’s statements were voluntary and admissible despite finding that his detention violated the Fourth Amendment rule requiring a prompt probable-cause determination after a warrantless arrest. The Court of Appeals denied interlocutory review, and the Michigan Supreme Court heard argument on Sanders’s application for leave to appeal.
The Court’s Holding
The Michigan Supreme Court held that statements made while an arrestee is detained in violation of the Fourth Amendment’s prompt-probable-cause requirement must be excluded unless the prosecution proves that the statements were sufficiently attenuated from the unconstitutional detention. Courts must consider whether Miranda warnings were given, the temporal relationship between the violation and the statements, any intervening circumstances, and the purpose and flagrancy of the police misconduct.
The Court explained that voluntariness is a separate threshold inquiry. A statement may be voluntary under the Fifth Amendment yet remain inadmissible as the product of an unlawful Fourth Amendment seizure. The Court therefore overruled People v. Manning to the extent it treated the voluntariness analysis as sufficient to address statements obtained during such unconstitutional detention.
Because the trial court considered only voluntariness and did not conduct the required attenuation analysis, the Supreme Court vacated the order admitting Sanders’s statements and remanded for further proceedings. It did not decide whether the statements were voluntary or ultimately admissible.
Key Takeaways
- Statements obtained during detention that violates the 48-hour probable-cause rule are subject to the Fourth Amendment exclusionary rule.
- The prosecution bears the burden of proving that a challenged statement was sufficiently attenuated from the unlawful detention.
- Voluntariness and attenuation are distinct inquiries; a voluntary statement may still require suppression because of a Fourth Amendment violation.
- The Court vacated the admissibility ruling but left the ultimate suppression decision to the trial court on remand.
Why It Matters
The decision establishes a new controlling framework in Michigan for statements obtained after warrantless arrestees have been held too long without judicial review. Miranda warnings and a finding of voluntariness do not alone cure the consequences of an unconstitutional detention.
The ruling also gives police agencies a strong incentive to obtain probable-cause determinations within 48 hours. Evidence of recurring practices based on an incorrect longer deadline may weigh toward suppression under the purpose-and-flagrancy component of the attenuation analysis.