The U.S. Supreme Court on Tuesday overturned a federal appellate court ruling which had voided the confession -- and conviction -- of a teen in connection with the state's largest mass murder.
In an unsigned order, the justices directed the 9th Circuit Court of Appeals to revisit its ruling which had concluded that Jonathan Doody had been illegally coerced into confessing killing nine people in 1991 at a Buddhist temple in west Phoenix.
Tuesday's order does not direct the appellate court to allow the conviction to stand. But it gives the appellate judges a different standard by which to measure the legality of the tactics used by Maricopa County sheriff's detectives to obtain the confession.
Doody's attorneys argued that the length of his interrogation by police, which began in the evening and continued for nearly 13 hours without significant breaks, indicates that he did not confess voluntarily.
They also said his statement should have been suppressed because he did not have a parent or guardian present. He was 17 at the time of questioning.
But the central question could be whether Doody was properly advised of his rights before he confessed.
Doody admitted to being at the scene but said he remained outside. Another teen, Alessandro Garcia, an accomplice, agreed to plead guilty and testified that Doody shot the victims in the head with a .22 caliber rifle as he watched from the doorway.
Prosecutors said the youths went to the temple in hopes of stealing large amounts of gold they believed they would find. Investigators said the robbery netted $2,650 and some electronic equipment.
Murdered were six Thai Buddhist monks, an elderly woman described as a nun and two young men who helped or studied at the temple.
Maricopa County Superior Judge Gregory Martin said he did not sentence Doody to death because he could not be sure which of the youths actually fired the shots.
The 9th Circuit ruling finding the confession involuntary was issued on Feb. 25 of this year.
Two days earlier, however, the U.S. Supreme Court issued a ruling of its own in a Florida case where a criminal defendant claimed he has been improperly advised of his Miranda rights. Those rights, first codified in 1966, require those suspects being questioned by police to be told of their right to remain silent, the right to consult with an attorney and the right to have that lawyer present during questioning.
In that case, the Supreme Court said the warnings given to the defendant, while they were not word-for-word what was sketched out in 1966, were sufficient to inform the defendant of his rights.
In Tuesday's order, the justices directed the 9th Circuit to revisit its order voiding Doody's confession in light of that Florida ruling.
In that order, the 9th Circuit said what should have been a simple warning to Doody :morphed into a 12-page exposition that negated the intended effect of the Miranda warning.'' More to the point, Judge Johnnie Rawlinson, who wrote the majority decision, said the detective's warnings were :far from clear and understandable.''
Rawlinson He said the verbal warning had :significant deviations'' from the printed form the detective was supposed to follow. And the judge said the detective repeatedly minimized the significance of those warnings to Doody.
For example, Rawlinson said the detective said Doody was entitled to an attorney if he had participated in a crime.
:The implication from this improperly qualified, unclear and confusing warning was that Doody only had the right to counsel if he were involved in a crime,'' the judge wrote. :In such a circumstance, the invocation of one's right to counsel would be tantamount to admitting one's involvement in a crime.''
It is possible that the 9th Circuit still could find the confession inadmissible even if the judges, under direction from the Supreme Court, find there was nothing wrong with the Miranda warnings. In tossing the confession, the appellate judges also found :that nearly 13 hours of relentless overnight questioning of a sleep-deprived teenager by a tag team of officers overbore the will of that teen, rendering his confession involuntary.''
Maricopa County sheriff's deputies had originally arrested four Tucson men after getting an anonymous tip. They subsequently made statements after questioning that implicated them in the crime.
Those confessions later were proven false and the county paid out $2.8 million in settlements.