People v. Valle

Defendant, age 18 at time of offense, was convicted of first-degree murder. Defendant alleged that certain inculpatory statements he made during two sessions of police interrogation, which was recorded on four DVDs, were involuntary. Court's review is not rendered de novo because statements in question were on video, but remains usual bifurcated standard for voluntariness. Defendant's claimed susceptibility to aggressive or deceptive interrogation techniques is an issue of fact, and live testimony by Defendant as to his status as a special education student in high school, and his lack of food and sleep during interrogation, and not only the videos, were relevant to court's suppression decision. Court properly admitted Defendant's statements, as court properly found that Defendant was not unusually susceptible to the police tactics of aggression and deception used. (HUTCHINSON and SCHOSTOK, concurring.)