State of Florida v. Penna
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In 2015, Zachary Penna committed a series of violent crimes in Florida, including two murders. After his arrest, Penna was read his Miranda rights and initially invoked his right to counsel. However, during his hospitalization, Penna voluntarily initiated several conversations with Deputy Michael Nettles, during which he made incriminating statements. Penna was subsequently charged with several crimes, including two counts of first-degree murder. Before trial, Penna moved to suppress the statements made to Deputy Nettles, arguing that they were obtained in violation of Miranda. The trial court denied the motion, and Penna was found guilty on all counts and sentenced to life in prison.
Penna appealed to the Fourth District Court of Appeal, which found that the statements during the first two conversations were not obtained in violation of Miranda. However, the court ruled that Deputy Nettles violated Miranda by failing to re-read Penna his Miranda rights prior to the final three conversations. The court relied on its own precedent, which had interpreted a previous Florida Supreme Court decision to require a full re-reading of Miranda warnings under the circumstances of this case. The court found that the error was not harmless, despite the overwhelming evidence of Penna’s guilt.
The Supreme Court of Florida accepted the case for review. The court was asked to consider whether a defendant’s Fifth Amendment Miranda rights are automatically violated when an officer fails to re-read a Miranda warning following a defendant’s voluntary re-initiation of contact. The court held that there is no per se requirement that an officer remind or readvise a defendant of his Miranda rights. The court found that the Fourth District Court of Appeal had improperly expanded the requirements of Miranda and receded from its previous decision that had established a categorical rule requiring a full re-reading of Miranda warnings. The court remanded the case for reconsideration under the proper standard.
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