Anything Officers Say Can and Will Be Used Against Them: The Kansas Court of Appeals Finds Another Instance of a Detective Downplaying Miranda

State v. Reynolds, No. 126,940, 2025 WL 438959 (Kan. Ct. App. Feb. 7, 2025).

Author: Hadley Sayers, Staff Editor

Issue: Does a detective downplay the significance of the Miranda warning by saying that the warning is just part of their paperwork?

Answer: Yes.

Facts: Detective Garen Honn interrogated Henry Reynolds about allegations Reynolds’ ex-girlfriend made that he inappropriately touched their young daughter.  The detective asked Reynolds to take a lie detector test.  Before the test, Detective Honn read Reynolds his Miranda rights.  Detective Honn then told Reynolds that he was not under arrest and that he was giving the Miranda warning as part of his paperwork.  Reynolds waived his Miranda rights.  During the test, Reynolds confessed to touching his daughter, and the detective immediately arrested Reynolds for rape.  The trial court found Reynolds guilty of aggravated indecent liberties with a child.  Reynolds appealed, arguing that his confession was untrustworthy and involuntary.

Discussion: The Due Process Clause protects against involuntary confessions, or confessions motivated by coercion.  Voluntariness is determined from the totality of the circumstances, including both the nature of the interrogation and the accused’s characteristics.  A relevant detail of any interrogation is whether an officer satisfactorily read the accused the Miranda warning, apprising them of their constitutional rights—including silence and counsel.  In State v. Garrett, the Kansas Supreme Court clarified that an officer’s attempt to minimize an accused’s constitutional rights can contribute to a coercive atmosphere and lead to an involuntary statement.

Here, the Kansas Court of Appeals held that Reynolds’ confession was involuntary, in part because Detective Honn downplayed the Miranda warning by saying that it was just part of his paperwork.  The Court explained that Detective Honn’s actions were similar to those of the detective in Garrett, who told the defendant he needed to “jump through some hoops” before reading him his Miranda rights.  However, unlike in Garrett, the totality of the circumstances led to an involuntary confession.  The Court reversed the conviction and vacated the sentence.

Key Authorities: Miranda v. Arizona, 384 U.S. 436 (1966); State v. Garrett, 555 P.3d 1116 (Kan. 2024).