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Media > Newsletters > Law Enforcement Bulletin > October 2015 > State v. Williams 2015 Ohio 3968

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State v. Williams 2015 Ohio 3968

Question: Can a suspect give a knowing, intelligent and voluntary waiver of his Miranda rights, despite being on medication for bipolar disorder and depression?

Quick Answer: Yes. Courts will consider the totality of the circumstances including the age, mentality and prior criminal experience of the accused; the length, intensity and frequency of the interrogation; the existence of physical deprivation or mistreatment; and the existence of threat or inducement.

Facts: Williams was incarcerated on an unrelated crime when investigators received a DNA match on an unsolved rape from 1998. An investigator interviewed Williams at the corrections facility for about 25 minutes after obtaining a written and verbal waiver of his Miranda rights. Although Williams explained that he was receiving medication for his bipolar disorder and depression, he voluntarily spoke to the investigator and appropriately answered questions when asked. The officers did not deny Williams food, drink, or the opportunity to use the restroom during his brief questioning. Williams himself terminated the interview. Williams argued that because he was heavily medicated for his mental conditions, he could not have properly waived his right to remain silent under Miranda. The court reasoned that Williams was 38 years old, very familiar with the criminal justice system, managing mental illness, and the interview was a brief, onetime event. Therefore based on the totality of the circumstances, the waiver was made knowingly, intelligently, and voluntarily.

Keep in Mind: The mere fact that a suspect is receiving medication or suffering from mental illness does not preclude officers from being able to secure a valid Miranda waiver when being mindful of the factors outlined above.