TBA Law Blog

TBA Law Blog

Court Clarifies Relationship Between Statements to Police, Waiver of Miranda Rights

Posted by: Stacey Shrader Joslin on May 11, 2023

The Tennessee Supreme Court today upheld the conviction of Kemontea Dovon McKinney on first-degree murder and aggravated robbery charges, finding that his statements to detectives and waiver of Miranda rights were voluntary. The court also concluded that the evidence was sufficient to support the convictions. During his trial, McKinney unsuccessfully challenged the admission of statements made to detectives, arguing that he did not knowingly and voluntarily waive his Miranda rights. McKinney appealed to the Court of Criminal Appeals, which found that the trial court erred when it denied the motion to suppress. The appellate court found that an involuntary-confession claim is “inextricably linked” to a Miranda-waiver claim. It also found the evidence was insufficient to support the murder conviction. The Supreme Court reversed that decision finding that the voluntariness test is distinct from the Miranda test and that after separately applying both tests, the statements and the waiver were found to be voluntary.

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