STATE v. JOHN JACKSON, SC 18194
Judicial District of New Haven
Criminal; Search and Seizure; Emergency Exception to Warrant Requirement; DNA Evidence; Whether Defendant Abandoned Expectation of Privacy in Property; Whether DNA Evidence Produced on eve of Trial Should have been Precluded Under General Statutes § 54-86k; Whether Defendant's Statements were Involuntary. The defendant, who had checked into a New York City hotel under an assumed name, attempted to commit suicide by jumping from his hotel room window. He landed on a lower roof and was hospitalized. On the same night, New Haven police discovered the dead body of the defendant's ex-girlfriend. After determining that the defendant was a suspect in the homicide, New Haven police traveled to New York to ascertain whether the person who attempted suicide was the defendant. At the hospital, the police questioned the defendant about his identity, and the defendant eventually gave them his real name. Thereafter, the police advised him of his Miranda rights. The defendant, who was on pain medication, made more statements but declined to sign a written waiver of his Miranda rights. Without a warrant, the police retrieved socks that they found on the lower hotel roof and a belt that New York police had seized from the defendant's hotel room. Subsequently, the defendant was charged with murder. Following jury selection, the state produced a forensic report showing that reddish-brown stains on the socks and belt fit the victim's DNA profile. The defendant filed a motion to suppress the socks and belt on the ground that they had been seized without a warrant. The trial court denied the motion to suppress, finding that when the defendant jumped out of the hotel window, he abandoned his expectation of privacy in those items. Moreover, it determined that the socks were in plain view and that the seizure of the items was justified under the emergency exception to the warrant requirement. The defendant also moved, pursuant to General Statutes § 54-86k, to preclude the DNA evidence because of the state's late disclosure of the report. The court denied the motion to preclude but sua sponte continued the trial for one month. In addition, the defendant moved to suppress his statements made at the hospital. In denying this motion, the court determined that the defendant was not entitled to Miranda warnings prior to being asked his name because he was not in custody and under interrogation. It rejected his claim that his hospitalization was sufficient to establish that he was in custody. Further, the court disagreed that the defendant’s statements were involuntary due to his being on pain medication. On appeal, the defendant claims that the trial court improperly denied his motions to suppress and should have precluded the DNA evidence.