The Washington Supreme Court ruled last week that Renton police violated a murder suspect’s constitutional rights during an early interrogation but said the error did not require overturning his conviction, according to a court opinion.
In a unanimous decision, the court said police subjected Cristian A. Magaña Arévalo to an interrogation on Dec. 1, 2018, without providing Miranda warnings, which violated his Fifth and Fourteenth Amendment rights.
The justices ruled those statements should not have been admitted at trial but concluded the error was harmless beyond a reasonable doubt because of other evidence and later statements that were properly admitted.
The case stems from the fatal shooting of Jason Hobbs outside an apartment complex in Renton on Nov. 30, 2018.
Surveillance video showed Hobbs arriving at the complex, following a dark-colored SUV on foot, and being shot multiple times at close range.
Hobbs died at the scene.
Police identified Magaña Arévalo as a person of interest and arrived at an apartment where he was staying with his partner and young child around 6 a.m. the next day.
Officers used a bullhorn to order the family out, separated Magaña Arévalo from his family, zip-tied his wrists, placed him in a patrol car and drove him to a nearby police staging area.
There, detectives interviewed him in the back of an unmarked police vehicle.
Although officers told him he was not under arrest and free to leave, he had not been given Miranda warnings.
During the interview, Magaña Arévalo discussed his relationship with Hobbs, an earlier encounter with him at a Subway restaurant, and a prior shooting at his uncle’s home where his partner and child had been present.
The Supreme Court said those circumstances — including the early-morning police operation, physical restraint, separation from family, and questioning in a police-controlled setting — meant a reasonable person would not have felt free to leave.
“Courts must consider the totality of the circumstances — not just one officer’s assertion that a suspect is ‘not under arrest,’” the opinion said.
Two days later, police interviewed Magaña Arévalo again at his partner’s apartment.
He was not restrained and the court said that interview was voluntary.
Although he still was not given Miranda warnings, the court ruled the earlier violation did not taint the later statements under federal constitutional law.
At trial, prosecutors played portions of both interviews and presented surveillance video and other physical evidence.
A jury convicted Magaña Arévalo of first-degree murder, and he was sentenced to 320 months in prison, plus 60 months for a firearm enhancement.
While the Supreme Court agreed that the trial court erred by admitting the Dec. 1 statements, it said the same information was repeated in the later interview and in Magaña Arévalo’s trial testimony, and that the state’s other evidence was strong.
The court used the case to clarify that courts must weigh both the strength of properly admitted evidence and the prejudicial impact of improperly admitted evidence.
Applying that standard, the justices affirmed the conviction and the earlier Court of Appeals ruling.