Prosecutors can’t use a statement a York County man gave to police regarding the heroin-related death of his 17-year-old girlfriend because he wasn’t read his rights before being questioned, a state court panel has ruled.
The Superior Court ruling precludes the district attorney’s office from pursuing a drug delivery resulting in death charge against 20-year-old Tyler Shane Valentine of New Freedom.
Kyle King, a spokesman for the district attorney’s office, said Tuesday that no decision had been made on whether to appeal the Superior Court’s ruling to the state Supreme Court.
Valentine was arrested by Southern Regional Police soon after authorities said Alexandra Marie Sneed, a senior as Susquehannock High School, died on Feb. 13, 2014 from a drug overdose after taking heroin in Valentine’s bedroom.
In a recorded statement he gave to investigators that same day, Valentine admitted to buying the heroin in Baltimore that Sneed ingested before her death, court records show.
The district attorney’s office appealed to the Superior Court after county Judge Gregory M. Snyder in December ruled that prosecutors can’t use Valentine’s statement at trial because he wasn’t read his Miranda rights, including his right to remain silent and to have an attorney present during questioning.
As a result, Snyder dismissed the drug-related death charge. He let stand other lesser counts including possession of marijuana and drug paraphernalia and corruption of minors.
On appeal, prosecutors took issue with Snyder’s conclusion that Valentine should have been given a Miranda warning before being questioned because he was subjected to a “custodial police interrogation” for which such warnings are mandatory. The DA’s office argued that Valentine wasn’t under any form of custody, and was free to leave the police station, so no rights reading was required.
Judge Judith Ference Olson disagreed in the Superior Court’s opinion.
Olson cited testimony that investigators told Valentine’s mother that he “must go to the police station” for questioning. Also, she noted that a detective began the questioning by telling Valentine “you can leave when you’re done here.”
“That Mr. Valentine was ‘in custody’ during the…police station interview is supported by the facts and the law,” Olson wrote. “A reasonable person in Mr. Valentine’s position would not believe that he was permitted to leave until he answered all of (the detective’s) questions.”
“The statements Mr. Valentine made during that interrogation must be suppressed,” she concluded.