State v. Howard
Annotate this CaseDefendant was charged with second-degree sexual abuse and child endangerment causing bodily injury after he admitted to sexually abusing a seventeen-month-old. Defendant moved to suppress his confession, claiming it was involuntary because the detective made promises of helping Defendant if he admitted to the crime. The district court denied the motion, holding that a promise to get help for a defendant does not constitute a promise of leniency. Defendant was found guilty of the charges. Defendant appealed the denial of his motion to suppress. The court of appeals affirmed, holding that the detective's statements about getting Defendant help were not impermissible promises of leniency. The Supreme Court vacated the court of appeals, reversed the judgment of the district court, and remanded the case for a new trial on both counts, holding (1) the interrogation of Defendant crossed the line into an impermissible promise of leniency, rendering the confession that followed inadmissible; and (2) the error was not harmless.
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