Whether a criminal defendant's confession was involuntary and obtained in violation of his Fifth Amendment right against self-incrimination when law enforcement allegedly used coercive interrogation techniques

No question identified. : denied Petitioner's direct appeal by published opinion issued July 16, 2025. See Exhibit "A". A Petition for Rehearing was denied on September 3, 2025. See Exhibit "B". The Petition for a Writ of Certiorari to the Oklahoma Court of Criminal Appeals is presently due in this Court on December 2, 2025. This application is not submitted at least ten days prior to the present due date for the petition for writ of certiorari. Therefore, Petitioner requests an extraordinary circumstance. Petitioner anticipated having the Petition completed by December 2, 2025. However, the issues being raised are complicated since the case is a capital case, and counsel is substitute counsel after the departure of both the attorney who originally briefed the case and the attorney who argued the case. This case presents a number of complex federal constitutional issues including but not limited to, whether the state court’s holding regarding Mr. Reece’s confession being a free and unconstrained choice by him and not a violation of his right against self-incrimination in violation of this Court’s multiple cases on the issues of coerced confessions. WHEREFORE, Petitioner respectfully requests an additional sixty (60) days to file his Petition for Writ of Certiorari, as allowed by Supreme Court Rule 13.5. Petitioner asks that an order be issued establishing the due date for Petitioner's Petition for Writ of Certiorari as January 31, 2026. Respegtfully submit ARVA ALICEA BANKS (OBA NO. 21593) Assistant Public Defender 611 County Office Building Oklahoma City, Oklahoma 73102 (405)7 13-1550 ATTORNEY FOR PETITIONER No. IN THE SUPREME COURT OF THE UNITED STATES OCTOBER TERM, 2025 WILLIAM LEWIS REECE, Petitioner, -vSTATE OF OKLAHOMA, Respondent. CERTIFICATE OF SERVICE I, Marva A. Banks, member of the bar of this Court, do hereby certify that I have served a copy of the Application for Extension of Time to File Petition for Writ of Certiorari to the Oklahoma Court of Criminal Appeals on counsel for the Respondent, State of Oklahoma, by depositing the same in the U.S. Mail, postage prepaid, to Jimmy Harmon, Chief of Criminal Division, Office of the Attorney General, 313 NE 21st Street, Oklahoma City, Oklahoma 73105, this 25th day of November, 2025. All parties required to be served have bee ed. MARVA ALICE BANKS IN THE SUPREME COURT OF THE UNITED STATES WILLIAM LEWIS REECE, Petitioner, vs. THE STATE OF OKLAHOMA, Respondent. APPLICATION FOR EXTENSION OF TIME TO FILE A PETITION FOR WRIT OF CERTIORARI TO THE OKLAHOMA COURT OF CRIMINAL APPEALS EXHIBIT "A" Original Opinion of the Oklahoma Court of Criminal Appeals in D-2021-867 Issued July 16, 2025 OKLAHOMA STATE COURTS */ NETWORK . Previous Case Top OfIndex This PointinIndex Citationize Next Case REECE v. STATE 2025 OK CR 10 Case Number: D-2021-867 Decided: 07/16/2025 Mandate Issued: 07/16/2025 THE COURT OF CRIMINAL APPEALS OF THE STATE OF OKLAHOMA Cite as: 2025 OK CR 10,__P.3d__ IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF OKLAHOMA WILLIAM LEWIS REECE, Appellant, v. THE STATE OF OKLAHOMA, Appellee. OPINION LEWIS, JUDGE: {1 William Lewis Reece, Appellant, was tried by jury on Murder in the First Degree, in violation of 21 O.S.Supp.1997,_§ 701.7 (A), in the District Court of Oklahoma County, Case No. CF-2015-6989, before the Honorable Susan Stallings, District Judge. The jury found Reece guilty and sentenced him to death after finding the following aggravating circumstances: (1) the defendant was previously convicted of a felony involving the use or threat of violence to the person; (2) the murder was especially heinous, atrocious, or cruel; (3) the murder was committed for the purpose of avoiding or preventing a fawful arrest or prosecution; and (4) the existence of a probability that the defendant would commit criminal acts of violence that would constitute a continuing threat to society. See 21 0.S.1991,_§ 701.12 (1), (4), (5), and (7). The trial court later sentenced Reece in acco