The N.C. Court of Appeals ruled yesterday that a Durham teenager accused of assault with a firearm on a law enforcement officer may have voluntarily waived his Miranda rights at a local emergency room, even though he was under the influence of the powerful painkiller Fentanyl. The case will receive a new hearing.
We covered the case of Rahmil Ingram last year. In a pretrial hearing, his attorney argued that Ingram’s admission to law enforcement officers—specifically, that he was armed with a shotgun during a police encounter in his home—should not be introduced into the trial. Ingram made the admission to an SBI agent while he was lying on a bed at Duke University Hospital, after two Durham police officers shot him at his house. Shortly before Ingram’s admission, hospital personnel had administered three doses of Fentanyl.
Ingram argued that law enforcement officers coerced him into waiving his Miranda rights and making the incriminating statement; the officers, he argued, sought to delay more painkilling medication during his police interview.
The trial judge ruled that Ingram’s statement was inadmissible, and that his waiver of his Miranda rights was involuntarily, considering the Fentanyl. Durham prosecutors appealed the judge’s ruling, sending the matter to the Court of Appeals prior to his trial.
In yesterday’s ruling, the appeals court ruled that the judge failed to determine whether Ingram was truly coerced into making incriminating statements. The appellate judges also ruled that the trial judge failed to make any specific findings as to Ingram’s mental condition, understanding or coherence, which are relevant factors in determining whether a defendant’s Miranda waiver is truly involuntary.
On Jan. 24, 2012, Durham police stormed Ingram’s house to execute a search warrant. Ingram maintains that when he heard the officers enter his building, he mistook them for intruders. He grabbed a shotgun and entered the hallway to confront the visitors. He claims that his hands were in the air when the police shot him. The police counter that they shot Ingram as he pointed his gun at them. The bullets struck Ingram in the back of the shoulder and buttocks.
A nurse reported that Ingram was in pain upon checking into the hospital, alternating between yelling and crying loudly. But the SBI agent who questioned him testified that Ingram was lucid when he waived his Miranda rights.