(CN) – A convicted murderer lost his bid for habeas relief on Monday with the Supreme Court unanimously finding that he failed to show an error by the Ohio courts that affirmed the verdict.
Confessions and a trial record reflects that Archie Dixon and Tim Hoffner murdered Chris Hammer to steal his car in 1993. After beating and tying up Hammer, Dixon and Hoffner buried their victim alive. Dixon forged Hammer’s identity to establish ownership of Hammer’s car, which he sold for $2,800.
The Ohio Supreme Court affirmed the conviction of murder, kidnapping, robbery and forgery against Dixon after concluding that the defendant’s confession was admissible since police had apprised him of his Miranda rights.
A federal judge also denied relief, but a divided 6th Circuit disagreed. It issued the writ of habeas corpus after finding that Ohio’s high court committed three egregious errors.
The federal appeals court said Dixon had declined to speak to police without his lawyer when he heard his Miranda rights five days before he later confessed. But the U.S. Supreme Court said Monday that Dixon was not in custody during the first police encounter and would not have the right to invoke his rights “anticipatorily.”
The justices also disagreed that Dixon identified a Fifth Amendment violation in the cops’ suggestion that he cut a deal before his accomplice decided to cut one.
Finally, the high court also said there was nothing to suggest that Dixon’s statements to the police were anything but voluntary.
“The admission of Dixon’s murder confession was consistent with this court’s precedents: Dixon received Miranda warnings before confessing to Hammer’s murder; the effectiveness of those warnings was not impaired by the sort of “two-step interrogation technique” condemned in [Missouri v.] Seibert; and there is no evidence that any of Dixon’s statements was the product of actual coercion,” the unsigned opinion states. “That does not excuse the detectives’ decision not to give Dixon Miranda warnings before his first interrogation. But the Ohio courts recognized that failure and imposed the appropriate remedy: exclusion of Dixon’s forgery confession and the attendant statements given without the benefit of Miranda warnings. Because no precedent of this court required Ohio to do more, the Sixth Circuit was without authority to overturn the reasoned judgment of the state’s highest court.”