Court of Appeals Reverses Manslaughter Conviction Because Trial Court Erroneously Precluded Voir Dire Questioning About Involuntary Confessions

On December 22, 2016, the Court of Appeals unanimously reversed the criminal conviction of OAD client James Miller. Mr. Miller, who was charged with a homicide, made statements to the police admitting his involvement in a shooting. At trial, Mr. Miller testified that his previous confession was false and was coerced by the police. Nonetheless, when counsel asked to voir dire prospective jurors about their ability to disregard a confession they deemed involuntary, the trial court denied the request based, in part, on the District Attorney’s indecision about whether to introduce the confession at trial. The Court of Appeals reversed, finding that “the trial court abused its discretion when it entirely precluded questioning on the issue of involuntary confessions and refused to make its own inquiry of the potential jurors on the issue.” In so holding, the court noted that defense counsel’s proposed questioning “went to the heart of determining whether those jurors could be impartial and afford defendant a fair trial,” Mr. Miller was “facing the most serious charge of murder,” and Mr. Miller’s defense was “premised . . . on the involuntariness of his inculpatory statements.” Mr. Miller is represented by volunteer attorney Daniella Main, of Alston & Bird LLP, and Margaret Knight. To read the decision, click here.