The Florida Supreme Court on Thursday overturned an appeals court decision that suppressed incriminating statements made by a man accused in a 2015 crime spree that included the stabbing deaths of two people in Palm Beach County.
In doing so, justices rejected a 2018 legal precedent about certain situations when suspects make statements to police without Miranda rights being administered.
Attorney General Ashley Moody’s office went to the Supreme Court in 2022 after the 4th District Court of Appeal said Zachary Penna should receive a new trial because a deputy did not give Penna his Miranda rights, which include the right to remain silent.
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Penna had been convicted of two counts of first-degree murder, one count of robbery with a weapon and one count of false imprisonment with a weapon. Along with the two stabbing deaths in Palm Beach County, he was accused of crimes including stabbing another man and a police dog in Brevard County.
Penna was shot by police and hospitalized.
A detective advised Penna of his Miranda rights, but Penna invoked his right to an attorney.
Weeks later, Penna made incriminating statements to a deputy who was guarding him at the hospital. The Supreme Court opinion said that the deputy “cautioned Penna against talking unless he wanted to” but did not give Miranda warnings.
The deputy testified about the conversations at Penna’s trial, but the appeals court said parts of the testimony should not have been allowed.
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Justices on Thursday, however, rejected a 2018 Florida Supreme Court ruling that was a basis for the appeals court decision.
In a 6-1 opinion, the Supreme Court said the 2018 ruling was “clearly erroneous” and that there is no “per se requirement that an officer remind or readvise a defendant of his Miranda rights.”
The opinion, written by Justice Jamie Grosshans and joined by Chief Justice Carlos Muniz and Justices Charles Canady, John Couriel, Renatha Francis, and Meredith Sasso, sent the case back to the appeals court for reconsideration.
Justice Jorge Labarga dissented, pointing to part of the Florida Constitution that protects against self-incrimination.
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