Major Florida Court: No Miranda Violation in Late-Night Murder Confession

October 9, 2025 Don Pumphrey, Jr. Criminal Defense, Violent Crimes Social Share

Florida’s First District Court of Appeal rules that a confession from a defendant who claimed to have insomnia and to be under the influence of drugs was voluntarily given.

What Are Miranda Rights?

In Florida, someone must be read their Miranda rights before police subject them to custodial interrogation. Your Miranda rights include all of the following:

• The right to remain silent
• The fact that anything you say can and will be used against them in a court of law
• The right to an attorney, including to have one during police questioning
• The fact that if you can’t afford an attorney, one will be provided for you

Note: For Miranda purposes, custody occurs when a reasonable person in the suspect’s position would not feel free to terminate questioning and leave. Interrogation occurs when police engage in questioning (or its functional equivalent) that is reasonably likely to elicit an incriminating response from a suspect.

When someone is read their Miranda rights, the smart move is to exercise them. Tell the police that you will be remaining silent, not answering their questions, and ask for an attorney. 

Actually speak these words aloud. If you do not say any of this (and simply sit there quietly), police can continue questioning you. Berghuis v. Thompkins, 560 U.S. 370 (2010)

When does someone validly waive their Miranda Rights?

If someone waives their Miranda rights and agrees to speak with law enforcement without an attorney present, such a waiver must be knowing, intelligent, and voluntary. Such a waiver must not be the product of police force, coercion, or someone’s ignorance of their rights – it must be informed and done of a suspect’s own free will. Miranda v. Arizona, 384 U.S. 436 (1966)

If a Miranda waiver was not made knowingly, intelligently, and voluntarily, any statements made by a suspect to law enforcement following their arrest are inadmissible in a court of law. This includes confessions to a crime, as Miranda is a “prophylactic rule.” Ross v. State, 45 So.3d 403 (Fla. 2010)

Can move to prevent their post-Miranda statements from being used against them at trial?

In some cases, a defendant will challenge the use of their post-Miranda statements in court. They may argue that their waiver was not knowing, intelligent, and voluntary – and as a result, their statements should be ruled inadmissible at trial. The likelihood of such a challenge succeeding depends heavily upon the facts of a given case.

In the decades after Miranda v. Arizona was decided, Florida courts have heard many challenges from defendants arguing their waivers were not knowing, intelligent, and voluntary. One of these challenges was recently decided by Florida’s First District Court of Appeal, in which a defendant argued his mental state at the time of his confession to murder made it involuntary.

Major New Case: Easterling v. State, 410 So.3d 750 (Fla. 1st DCA, May 2025)

In Easterling, the defendant (Easterling) was convicted of first-degree murder. He challenged his conviction on two grounds – the first being that the State did not prove the murder of the victim was premeditated (time to reflect before the killing, required to be proven for first-degree murder conviction). The 1st DCA disagreed, and affirmed on this point.

Next, Easterling challenged the use of his confession against him at trial. He asserted that the trial judge erroneously denied his motion to suppress his confession to law enforcement. He asserted that his confession was not freely and voluntarily given.

Easterling argued that he was under the influence of a high dosage of benzodiazepine and other medications. Moreover, he claimed he was suffering from insomnia due to a mental condition, and was sleep deprived at the time of the confession (which occurred in the middle of night).

Despite Easterling’s claims, the 1st DCA upheld the use of his confession at trial – affirming his first-degree murder conviction. The court noted that Easterling was read his Miranda rights and waived them in a manner that appeared to be knowing, intelligent, and voluntary.

Moreover, the 1st DCA wrote that the trial court’s ruling was supported by the video recording of Easterling’s confession:

“The statement was recorded on video from two angles. In denying the motion to suppress after viewing the videos of the confession, the trial court stated, ‘I saw no slurring. I saw no mumbling. I saw no grogginess. I saw responsiveness. I saw alertness. I saw appropriate answering of questions.’”

The 1st DCA observed that “severe intoxication or inebriation that ‘rises to the level of mania’ can be grounds to suppress a statement made during custodial interrogation – per Rigterink v. State, 193 So. 3d 846, 865 (Fla. 2016). But the court found that Easterling was in no such state when he spoke with officers, concluding:

“[H]ere, competent, substantial evidence supports the trial court’s finding that Easterling was not even impaired. The trial court appropriately denied the motion to suppress Easterling’s confession.”

Takeaways From Easterling

The 1st DCA’s Easterling decision indicates that there must be actual evidence that someone is impaired to the point of being unable to make a voluntary confession, for this to be admitted. Even if Easterling was not misrepresenting his condition at the time of the interrogation, there was nothing on video clearly showing he was under the influence or suffering from insomnia.

Following this decision, critics may argue that the burden of proof was inverted in Easterling’s case. The State must prove by a preponderance of the evidence that a defendant’s post-Miranda statements were knowing, intelligent, and voluntary. Ross v. State, 45 So. 3d 403 (Fla. 2010). Here, critics may say, it seemed that Easterling had to prove he was intoxicated. 

Whether or not Easterling was actually under the influence and suffering from insomnia, the ruling in this case is clear. A defendant’s claims regarding their mental state post-Miranda cannot alone serve as the grounds for suppressing their statements. They must be supported by evidence from the interrogation itself (claiming to not understand what officers are saying, etc.).

In sum, Easterling is a significant new case on Miranda rights in Florida. Going forward, the ruling may make it harder for defendants (including in Tallahassee and Northwest Florida) to claim their mental state made them unable to give a voluntary confession. However, its impact will only be fully realized with the passage of time.

If someone is concerned that their Miranda waiver was not knowing, intelligent and voluntary, it is crucial to find experienced and aggressive legal representation as soon as possible. This vital decision could make the difference in whether or not a person is subject to a lengthy prison term and hefty fines. 

Criminal Defense Attorney in Tallahassee, FL

Don Pumphrey, Jr. is a Former Prosecutor, Former State Police Officer, Lifetime Member of the Florida Association of Criminal Defense Lawyers; for over 25 years as a private defense attorney who is Trusted, Experienced, Aggressive in Criminal Defense as a Trial Attorney, Criminal Lawyer, Criminal Defense Lawyer for the accused in Florida State Courts located in Tallahassee, Florida but handling cases throughout the State of Florida.

Don Pumphrey, Jr. and the Tallahassee criminal defense lawyers at Pumphrey Law have decades of experience fighting drug charges on behalf of clients and winning. Call Pumphrey Law now at (850) 681-7777 to learn more about what we can do for you. Our lawyers will be happy to provide you with a free consultation.

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