State v. Johnson

Source Status

✔ Original opinion obtained, reviewed, and verified

✔ Relevant passages highlighted.

✔ Publicly available copy located through North Carolina case law records

✔ Included within the Source Verification Archive

Cited to Support

May's reliance upon State v. Johnson, 371 N.C. 870, 821 S.E.2d 822 (2018), for the legal standard governing the voluntariness of confessions under the Fifth and Fourteenth Amendments. The Johnson decision is cited to establish that courts must determine whether a defendant's will was overborne by examining the totality of the circumstances surrounding the confession and considering factors including: (1) the circumstances of the interrogation, including location, restraints, and access to family members or counsel; (2) the treatment of the suspect, including the duration of questioning, availability of food, drink, breaks, and restroom access; (3) the appearance and demeanor of law enforcement officers; (4) statements made by officers, including threats, promises, trickery, or deception; and (5) characteristics of the defendant, including age, mental condition, familiarity with the criminal justice system, and demeanor during questioning.
May relies upon Johnson to frame his argument that the circumstances of his detention and interrogation—including continuous custody, restraints, fatigue, delayed Miranda warnings, alleged promises of release, mental-health issues, intoxication, and youth—must be evaluated collectively when determining whether his statements were knowing, voluntary, and admissible.

Supporting Documents

Original Article

Link to the original document.

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Highlighted Research Copy

Working research copy containing the highlighted passages cited in the Supplemental Motion.

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