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State v. Robinson

The interviewing officer induced a portion of the defendant's custodial statement by hope of benefit when he implied that the defendant would receive a lighter sentence if he cooperated with police.

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The State brings this appeal from an order of the trial court granting in part Paris Robinson’s motion to suppress statements he made to police during a custodial interview. As grounds for its appeal, the State asserts that the trial court erred when it found that a portion of Robinson’s police interview was inadmissible because it was induced by a statement of the interviewing officer which implied that Robinson would receive a lighter sentence if he cooperated with police. For reasons explained below, we find no error and affirm.

The relevant facts are largely undisputed, and the record shows that in August 2011, the Savannah-Chatham Metropolitan Police Department was investigating a series of armed robberies targeting Hispanic males at or near apartment complexes on the south side of Savannah. As part of the investigation, police began conducting stakeouts at various apartment complexes in the southern part of the city. During a stakeout on the night of August 5, 2011, an officer encountered a group of men, including Robinson, running away from one of the apartment complexes; the men were being followed by a large group of Latino men. The officer saw Robinson raise a pistol upward and heard a shot fired. After briefly investigating the incident, police arrested Robinson and two other individuals. During a search of Robinson’s person, police found a wallet and car keys that had been stolen from one of the men in the pursuit group. Police subsequently conducted an identification show up at the scene, and one of the victims identified Robinson and at least one other individual as having been involved in a robbery that evening.

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