Ezekiel Isiah Delgado v. Neil McDowell, Warden
CriminalProcedure HabeasCorpus JusticiabilityDoctri
Did the Court of Appeal unreasonably apply Supreme Court Miranda precedents by admitting Delgado's second confession without curative measures after deliberately violating his Miranda rights?
QUESTION PRESENTED Delgado was convicted of two counts of first degree murder. In a published decision, the California Court of Appeal held that detectives violated then-sixteen year old Delgado’s Miranda rights when they obtained a confession. However, the Court of Appeal found that Delgado’s subsequent warned statement, which was taken during a single continuous interrogation, was properly admitted as evidence at trial. The question presented is: Did the Court of Appeal decision affirming the admissibility of Delgado’s second confession unreasonably apply this Court’s decisions in Miranda v. Arizona, 384 U.S. 436 (1966), Oregon v. Elstad, 470 U.S. 298 (1984) and Missouri v. Seibert, 542 U.S. 600, 608 (2004) because the detectives obtained Delgado’s second confession without taking any steps to cure their violation of his Miranda rights?