The Supreme Court has reinstated a conviction against an Ohio man accused of burying his roommate alive. In a per curiam opinion, the Court overturned the Sixth Circuit Court of Appeals, which previously ruled that police coerced the murder suspect's confession.
Archie Dixon and Tim Hoffner murdered Chris Hammer in order to steal his car. The men beat Hammer, tied him up, and buried him alive; pushing the still-struggling victim down into his grave while they shoveled dirt on top of him. Dixon then used Hammer's birth certificate and social security card to obtain a state identification card in Hammer's name. Using that identification card to establish ownership of Hammer's car, Dixon sold the vehicle for $2,800.
The police had several conversations with Dixon while investigating Hammer's murder. On one of those occasions, police provided Dixon with Miranda warnings, and he refused to speak to them.
After determining that Dixon had sold Hammer's car and forged Hammer's signature when cashing the check he received in that sale, police arrested Dixon for forgery. Prior to a multi-hour interrogation in conjunction with the forgery arrest, detectives decided not to provide Dixon with Miranda warnings for fear that Dixon would, again, refuse to talk. Dixon admitted to the forgery, but said that he had sold the car with Hammer's permission. He denied any knowledge of Hammer's whereabouts.
Later that day, Hoffner led police to Hammer's body.
Dixon returned to the police station that night, and told police that he wanted to tell them what had happened. Officers twice provided Dixon with Miranda warnings, and Dixon signed a waiver of those rights. In a recorded confession, Dixon admitted his involvement, but tried to pin most of the blame on Hoffner.
An Ohio trial court excluded both Dixon's initial confession to forgery and his later confession to murder. The State appealed, arguing that the murder confession was admissible because Dixon had received Miranda warnings prior to that confession. The Ohio Court of Appeals agreed and allowed Dixon's murder confession to be admitted as evidence. Dixon was convicted of murder, kidnapping, robbery, and forgery, and sentenced to death.
The Ohio Supreme Court affirmed Dixon's convictions and sentence. The Sixth Circuit Court of Appeals reversed, finding that Miranda directly applied, and that police should not have spoken to Dixon on the day of his confessions because Dixon refused to speak to them days earlier without a lawyer present.
The Supreme Court reversed the Sixth Circuit, finding that a person cannot invoke his Miranda rights anticipatorily, in a context other than custodial interrogation. The Court also found that the Sixth Circuit erred in ruling that the police could not urge Dixon to confess before Hoffner.
Finally, the Supreme Court ruled that the Sixth Circuit Court of Appeals erred in striking Dixon's later confession under Missouri v. Seibert. Unlike Seibert, the Court found that there was "no nexus" between Archie Dixon's unwarned admission to forgery and his later, warned confession to murder.
- Bobby v. Dixon (Supreme Court)
- Sixth Circuit: No Habeas Relief From Procedural Default (FindLaw's Sixth Circuit blog)
- Court reverses decision throwing out death sentence for man convicted of burying victim alive (The Washington Post)
- Troy Davis Case: Should Supreme Court Have Stayed Execution? (FindLaw's Supreme Court blog)