After Ten Years – Guilty Verdict Handed Down Yet Again for Murder Over Stolen Bike

April 5, 2022 Criminal Defense, Violent Crimes

On March 24th, 2022, Frank Quarles was found guilty of second-degree murder for a tragic crime that occurred in 2012. In the decade since the incident, the case has had a turbulent journey through the Palm Beach County court system – a journey that will be discussed and examined through this blog.

What Happened?

In 2017, Frank Quarles, who was 15 at the time, was convicted of second-degree murder, possession of a firearm by a minor, and carrying a concealed firearm in the death of 16-year-old Michael Robertson. Quarles and Robertson were classmates, and the act of violence occurred after Quarles saw Robinson riding the bike that was stolen from him weeks before. Quarles then went home and retrieved his father’s gun, which he used to fatally shoot Robinson. Quarles was tried as an adult and received a sentence of 35 years in prison.

However, the case took a turn in 2020, when the 4th District Court of Appeal overturned Quarles’ conviction because he was not properly advised of his right to remain silent under his Miranda rights. When Quarles was arrested and taken into custody, he was informed  of his Miranda rights by a detective and invoked his right to remain silent. He was brought to a holding cell, and about an hour later, he said he wanted to speak to a detective. When he was brought into the interrogation room, the detective asked him if he understood the discussion about his Miranda rights from earlier, although he was not re-read his Miranda rights. He then admitted to accidentally shooting Robertson. The appellate court emphasized their issue with the fact he was not re-read his rights in their opinion, stating:

Less than one hour later, Defendant changed his mind and wanted to speak with the detective. Although the detective did make a reasonable inquiry into whether Defendant remembered and understood his Miranda rights, and that his desire to speak with the detective was not coerced, the detective did not re-read to Defendant his Miranda rights. Under the Supreme Court’s mandate in Shelly, the detective’s failure to do so rendered Defendant’s confession involuntary.

In response to the error, Michael Salnick, attorney for Quarles at the time, stated, “he was a child” and the questioning “violated his basic constitutional rights.” Further, during the appeals process, Salnick argued that at one point, the detective told Quarles he could be sentenced to death, although the U.S. Supreme Court ruled in 2005 under Roper v. Simmons that it was unconstitutional to impose the death penalty for a crime committed by a child under the age of 18. “They messed with his head. They messed with his rights, and they lied to him,” Salnick explained.

Recent Case Progression

When the Florida Supreme Court refused to take on the case, a new trial was ordered. That trial took place on March 23, 2022. Quarles, now 25, faced a six-person jury who eventually found him guilty of second-degree murder. The jury ruled similarly to the jury who first heard the case in 2017 and found Quarles guilty of second-degree murder, rather than first-degree murder, noting that the killing was not premeditated. Assistant State Attorney Chrichet Mixon, who prosecuted the initial case in 2017 as well as the recent 2022, stated that the act of violence stemmed from Quarles feeling disrespected after discovering Robertson had his bike. According to a friend of Robertson who testified in 2017, “Robertson purchased the bike from someone in the neighborhood not knowing it was stolen and tried to sell it back to Quarles for $10 after Quarles tried to reclaim the bike. It took Quarles 20 minutes to take his bike back, ride home, pick up a gun he had hidden under his bed and ride back to the house” where he eventually shot Robertson.

Miranda Rights

Under Shelly v. State, there is “a requirement that the accused be specifically given his or her Miranda rights after an alleged reinitiation.”  Therefore, when an accused has invoked his or her right to counsel or silence and then has subsequently commenced a conversation with officers, the officers must re-read the accused their Miranda rights. To read more about navigating Miranda Rights in Florida, visit our blog here. Further, to read about a recent interesting case that hinged on whether the defendant gave a voluntary Miranda waiver, visit our blog here.

Tallahassee Criminal Defense Attorney

The case clearly illustrates the need for an educated Tallahassee criminal defense attorney that can advise their client on what is required by law enforcement officers when it pertains to Miranda rights. Don Pumphrey and the members of the legal team at Pumphrey Law Firm are well-versed in Miranda rights and will advocate zealously in your corner while ensuring your rights are upheld. Call (850) 681–7777 or send an online message to discuss your rights during an open and free consultation with a defense attorney on our legal team.

Written by Sarah Kamide

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