New Hampshire v. Marin

Defendant Katlyn Gage Marin was convicted in a bench trial of the second degree murder of her three-year-old daughter, Brielle Gage. Before trial, she moved to suppress statements she made to the police prior to being advised of her Miranda rights. The pre-Miranda statements at issue consisted of three sets of statements: given at her home, in a police cruiser, and in a family waiting room at the police station - each of which contained a different version of the circumstances giving rise to Brielle’s fatal injuries. She also argued that other statements that she made after she had been advised of her Miranda rights should be suppressed because they were tainted by the illegally-obtained pre-Miranda statements. After concluding that defendant was not in custody until after she was advised of her Miranda rights, the trial court denied the defendant’s motion. Finding no reversible error, the New Hampshire Supreme Court affirmed defendant's conviction. View "New Hampshire v. Marin" on Justia Law