Berghuis v. Thompkins

Facts

On January 10, 2000, a shooting outside a mall in Southfield, Michigan, killed Samuel Morris and wounded Frederick France. Thompkins, a suspect, fled. About one year later he was found in Ohio and arrested. Two Southfield officers went there to question him. The interrogation began around 1:30 p.m. and lasted about three hours, in an 8-by-10-foot room. Detective Helgert gave Thompkins a written form listing the Miranda warnings (the rights police must explain to a suspect in custody). Thompkins read the fifth warning aloud, and Helgert read the other four aloud. Thompkins declined to sign the form. The record conflicts on whether he said he understood his rights. He never said he wanted to remain silent, did not want to talk, or wanted a lawyer. He was largely silent, gave a few brief answers, and sometimes nodded. About 2 hours and 45 minutes in, Helgert asked whether he believed in God, whether he prayed to God, and whether he prayed to God to forgive him for shooting the boy. Thompkins answered yes to each. He refused to make a written confession, and the interrogation ended about 15 minutes later. The prosecution used those answers at trial, where the defense tried to blame Eric Purifoy, the van's driver. Purifoy had been tried earlier and acquitted of murder, and defense counsel did not ask for an instruction limiting how the jury could use that outcome. The jury found Thompkins guilty on all counts.

Issues

1. Did Thompkins invoke his right to remain silent by staying largely silent through nearly three hours of questioning, so that police had to end the interrogation?
2. Did Thompkins waive his right to remain silent by answering the officer's questions about God after receiving and understanding the Miranda warnings?
3. Did police have to obtain a waiver of Thompkins's Miranda rights before they began questioning him?
4. Did Thompkins show prejudice from his lawyer's failure to request a limiting instruction about the outcome of Purifoy's trial?

Holding

Thompkins did not unambiguously invoke his right to remain silent. By answering Helgert's questions voluntarily after understanding the warnings, he impliedly waived it, and police did not need a waiver before questioning him. He also could not show prejudice from the missing jury instruction.