Stephon Lindsay v. Alabama

After identifying Stephon Lindsay as the only suspect in the disappearance of his daughter, Maliyah, at least half a dozen law enforcement officers confronted Mr. Lindsay on the porch of a friend’s residence. Without advising Mr. Lindsay of his Miranda rights, officers began questioning him and obtained an inculpatory statement implicating Mr. Lindsay in Maliyah’s death. It was not until Mr. Lindsay was transported to the police station in Gadsden, Alabama, and placed in an interrogation room with his left wrist handcuffed to the wall that he was advised of his constitutional right not to incriminate himself. After waiving his Fifth Amendment rights, Mr. Lindsay confessed to killing Maliyah. Mr. Lindsay’s inculpatory statements to police were admitted against him at both phases of his capital trial. Assuming that Mr. Lindsay was in custody, the Alabama Court of Criminal Appeals held that the statements made on his friend’s porch were admissible at Mr. Lindsay’s capital trial despite the lack of Miranda warnings, pursuant to the “public safety exception” set forth by this Court in New York v. Quarles, 467 U.S. 649 (1984), and that Mr. Lindsay’s post-waiver statements were properly admitted because “[t]his is not one of those extreme cases where [Mr.] Lindsay’s mental condition rendered his confession involuntary.” Lindsay v. State, No. CR-15-1061, 2019 WL 1105024, at *17 (Ala. Crim. App. March 8, 2019). The lower court’s holdings give rise to the following important question: Can a court, consistent with Miranda v. Arizona, 384 U.S. 436 (1966), and its progeny, expand the narrow public safety exception to Miranda set forth in New York v. Quarles to include custodial interrogations aimed at locating a missing person?