Office of the Attorney General
SLIP OPINION
| AG number: 7029 | Style: Almeida vs. State (Ingangiola murder) |
| Jurisdiction: Florida Supreme Court | Date issued: July 8, 1999 |
Officer's duty to answer question about rights Police officers questioning a suspect must respond to a clear question regarding the suspect's rights with a good-faith attempt to provide accurate information before they may continue the interrogation, the Florida Supreme Court held. The court, in a 4-3 decision, reversed the murder conviction and vacated the death sentence Osvaldo Almeida received for the 1993 murder of Chiquita Counts in Fort Lauderdale. After Almeida confessed in preliminary questioning to the Counts murder and two others, officers began a recorded interview by asking Almeida - who had previously waived his Miranda rights - if he was willing to talk without a lawyer present. Almeida responded, "Well, what good is an attorney going to do?" The officers ignored the question and went on with the interrogation. The justices said Almeida's question was not rhetorical and required a good-faith response, and because it was not answered Almeida's confession should not have been admitted. "(W)e hold that if, at any point during custodial interrogation, a suspect asks a clear question concerning his or her rights, the officer must stop the interview and make a good-faith effort to give a simple and straightforward answer. To do otherwise - i.e., to give an evasive answer, or to skip over the question, or to override or "steamroll" the suspect - is to actively promote the very coercion that (case law) was intended to dispel. A suspect who has been ignored or overridden concerning a right will be reluctant to exercise that right freely. Once the officer properly answers the question, the officer may then resume the interview (provided of course that the defendant in the meantime has not invoked his or her rights). Any statement obtained in violation of this proscription violates the Florida Constitution and cannot be used by the State," the court said. However, the court in a separate opinion affirmed Almeida's conviction for the 1993 murder of Sunrise restaurant manager Frank Ingangiola. The court reversed Almeida's death sentence and ordered a life sentence without parole for at least 25 years, citing extensive evidence of Almeida's brutal childhood and mental health problems and calling the case "one of the most mitigated murders the Court has reviewed." |