Stechauner v. Smith

Dist. Ct. did not err in denying defendant’s habeas petition challenging his second-degree reckless homicide conviction on grounds that: (1) govt. violated Miranda by obtaining certain inculpatory statements while defendant was in custody at his hospital bed and during subsequent encounter defendant had with his friend; and (2) his trial counsel was ineffective for failing to call certain witnesses during his suppression hearing to establish that he was in custody while at hospital. Record showed that defendant was not in handcuffs while at his hospital bed when making his inculpatory statements, and statements made between defendant and his friend that were overheard by police regarding location of firearm did not constitute interrogation for purposes of Miranda. Also, fact that defendant may have been on pain medication at time of his hospital-bed statements did not render said statements involuntary. Also, trial counsel was not ineffective for failing to call several witnesses during suppression hearing, since none of defendant’s proposed witnesses could have corroborated his claim that he was in handcuffs at time of his hospital-bed statements. Similarly, counsel was not ineffective for failing to introduce certain hospital records which failed to support defendant’s claim that he was in police custody while in hospital.