(CN) – A full panel of the 9th Circuit overturned the conviction of a man who confessed as a teen to participating in the 1991 murders of nine people, including six Buddhist monks, at an Arizona temple. The Seattle panel said Johnathan Doody’s confession had been coerced “after nearly 13 hours of relentless overnight questioning … by a tag team of officers.”
Doody was a 17-year-old high-school student when he confessed to participating in the 1991 temple murders. The victims, including six Buddhist monks, two nuns and a novice were found lying face-down in a circle, each shot in the head, in the Wat Promkunaram Buddhist Temple near Phoenix.
Doody was arrested and later convicted for all nine murders. He was sentenced to 281 years in prison. Another minor, Alessandro Garcia, testified against Doody and was also convicted as an accomplice after pleading guilty. Garcia was sentenced to 271 years.
In a 106-page ruling, an 8-3 majority of the 9th Circuit ruled that Doody should be given a new trial, citing the extensive interrogation and inadequate Miranda warnings preceding Doody’s confession.
The majority ruled that the Miranda warnings administered by detectives were “far from ‘clear and understandable,'” and that the “Arizona Court of Appeals completely failed to consider the detective’s significant deviations from the printed Miranda form and his repeated minimizing of the warnings’ significance.”
The detective had “ad libbed that Doody had the right to counsel if Doody was involved in a crime,” Judge Johnnie Rawlinson wrote (original emphasis).
“We can readily discern from the audiotapes an extraordinarily lengthy interrogation of a sleep-deprived and unresponsive juvenile under relentless questioning for nearly 13 hours by a tag tem of detectives, without the presence of an attorney, and without the protections of proper Miranda warnings,” Rawlinson wrote.
Judges Richard Tallman, Pamela Rymer and Andrew Kleinfeld dissented, saying the majority “once again asserts its judgment for the judgment of a state trial court and a state court of appeals” (original emphasis).
Tallman said the question before the 9th Circuit was simply whether the Arizona courts “reasonably applied federal law” in concluding that Doody’s confession was voluntary.
In overturning the state courts, “the majority discards as objectively unreasonable the factual findings made by the trial court, the jury’s considered verdict, and the well-reasoned opinion of the Arizona Court of Appeals,” Tallman wrote.
The dissent also noted the state appeals court’s finding that although the interview lasted nearly 13 hours, Doody admitted to borrowing the murder weapon after about two and a half hours, and had begun to confess by six hours.
Doody and Garcia came under investigation after the owner of the murder weapon, a Marlin .22 caliber rifle, told detectives that the teens had borrowed the gun shortly before the murders.