Appeal of manslaughter conviction denied by Maine Supreme Court
The Maine Supreme Court denied an appeal by a former Knox man to reconsider his manslaughter conviction for fatally shooting his friend in February 2011.
According to previously published reports, Luke A. Bryant, 22, was convicted of killing a man he described at trial as his best friend, 19-year-old Tyler Seaney, at Bryant's Dolloff Road apartment in Knox on the night of Feb. 19, 2011. Bryant told police he was trying to clear his 12-gauge shotgun when he accidentally pulled the trigger as Seaney stepped out of the bathroom. The state alleged Bryant was engaged in a scare game with Seaney when he raised the shotgun in his friend's direction and pulled the trigger.
Bryant was indicted by a Waldo County grand jury May 20, 2011. He then filed a motion to suppress statements he made to the police, which was denied. After a three-day trial, he was found guilty and and was sentenced in October 2012 to 15 years in prison with all but nine years suspended, and four years of probation following release. Bryant appealed the conviction April 7, 2014.
Bryant argued in the appeal through his lawyer Steven C. Peterson that the court erred when denying his motion to suppress statements because he made them while in a custodial interrogation without having been read his Miranda warnings, and because his emotional state — the interviews with detectives Jason Bosco and Jason Andrews took place just after the shooting occurred — made his statements involuntary.
The Maine Supreme Court decided July 22 to uphold the district court's judgment after finding that Bryant was not in custody when he made the statements he wished to suppress, and that his statements were made voluntarily.
The decision written by Justice Warren M. Silver stated that custody refers to being placed under formal arrest or having one's freedom of movement restricted to a degree associated with formal arrest. Both parties agreed that Bryant was not under formal arrest. The court considered “whether a reasonable person standing in the defendant's shoes would have felt he or she was at liberty to terminate the interrogation and leave,” based on a number of factors including the degree of restraint placed on the suspect and the number of law enforcement officers present.
The decision stated the totality of the factors establishes that Bryant was not in custody at any point during the interviews conducted in the bedroom and police cruiser, or the walk-through reenactment in their apartment.
“Throughout the interviews, the detectives repeatedly asked Bryant's permission to speak with him, and Bryant repeatedly consented,” the decision states. “The detectives did not physically restrain Bryant and they repeatedly told Bryant that he was not under arrest and that he was free to terminate the conversation and leave at any time; in fact Bryant did leave at the end of the interviews. “
That there were only two plain-clothes officers present and that Bryant was familiar with the surroundings — the interviews took place in and around his home — also factored in to the court's finding that Bryant was not in custody. The court found Bryant's arguments that an officer was standing outside his bedroom sending the message that Bryant was not to leave, and that he was badgered into conducting a walk-through was not supported by the evidence. Rather, “Bryant displayed an eagerness to assist the detectives in their investigation,” the decision states.
To be voluntary, a confession must be the free choice of a rational mind, fundamentally fair, and not a product of coercive police conduct. The court considered a number of factors including the persistence of the officers, police trickery, the defendant's age, physical and mental health, emotional stability and conduct. The court found the statements were made voluntarily based on the non-custodial and non-confrontational nature of the interviews, and Bryant's composure throughout the interview.
“To the extent that Bryant was emotionally distressed by the shooting that had occurred, there is no evidence that such distress rose to the level of mental or emotional instability required to render his statements involuntary," Jutice Silver wrote in the decision.
The state was represented by Assistant Attorney General Lauren F. LaRochelle.