Com v. Yandamuri was a direct capital appeal case pursuant to the Court’s responsibility to directly review all death penalty cases. In a botched baby-kidnapping-for-ransom attempt, Raghunandan Yandamuri, a non-citizen, knocked on the door of the home of friends, forced entry and threatened the grandmother with a four-inch knife. The grandmother struggled when Yandamuri grabbed the baby, and he stabbed Grandmother in the throat several times, killing her. He then stuffed a cloth in the baby’s mouth, bound the baby’s head with a towel (to keep the cloth in place), and then stuffed the child in a suitcase and left the suitcase in a sauna while he showered.
Yandamuri’s “plan,” such as it was, unraveled when he used an identifiable term for the parents known to only a small group of friends on the ransom notes strewn about the scene of the crime. He was in a casino when approached by security and asked if he would meet police in a hallway. He complied, and voluntarily accompanied the police to the station, and from there, the story is simple. He was repeatedly told he could leave at any time, and as his story changed, he finally was read Miranda rights, and he gave a full confession.
Yandamuri’s challenge to his conviction for first-degree murder is as weak as his plan for ransom. He challenged his “detention,” the admissibility of his confessions and claimed that “discrepancies” in the stories of the Commonwealth’s witnesses constituted “false evidence.” These arguments were flatly rejected.
Baer for the Majority: No Custodial Interrogation, Miranda not Required
Justice Baer, speaking for the majority upheld the conviction. Yandamuri’s first argument is that he was illegally arrested and detained. But the facts clearly demonstrated that he was first approached by private security guards at the casino where he was gaming, and he agreed to go with the guards, then with the police, and that he voluntarily remained with the police at the station in an unlocked room, even after repeatedly being reminded he was free to leave.
Second, Yandamuri argued that his confessions were coerced because he was not Mirandized early enough in the process. In determining whether a Defendant was in custodial interrogation such that Miranda warnings are required, the courts use an objective test, asking whether a reasonable person would have believed he was at liberty to terminate the police encounter under the circumstances. In this case, the officers’ repeated reminders that he was free to leave, their offer that he take breaks for food or to use the restroom, and the fact that Mr. Yandamuri had a master’s degree, implying high intelligence that makes it unlikely he was psychologically coerced.
The Court notes only two factors in his favor: Yandamuri is not a citizen, and thus “may have been unfamiliar with police practices” here in America; and he was at the police station for thirteen hours before confessing—his final confession came early in the hours of the morning. But nothing else in the situation argued in favor of a coerced confession, and so the confession could be properly admitted.
Finally, the Court rejected Defendant’s argument that minor discrepancies in the testimony of witnesses for the Commonwealth constituted the presentation of “false evidence.” Discrepancies, by themselves, are not false evidence.
Conclusion: You Can Always Waive Your Rights
These cases are always heartbreaking—especially when they deal with a murdered baby, and a grandmother who tried, however futilely, to wrest the baby back from the kidnapper. This case provides little of interest to the practicing attorney, but reaffirms the basic principle that constitutional protections cannot be foisted on those who are not interested in preserving them. The evidence used to convict Yandamuri came largely from his own mouth.Read More