## Facts

- A store detective at an L.L. Bean store investigated a suspected theft after a man attempted to return a sweater without a receipt; store records indicated the sweater had been placed on the sales floor that day.
- The man stated the sweater belonged to a friend and that the friend and Sandra E. Coombs were in a car in the parking lot; the detective located the car and waited for police.
- A Freeport police sergeant approached the car, requested registration, and observed a small bag of marijuana when the glove box was opened; he confiscated it.
- Coombs voluntarily accompanied the store detective back into the store to discuss the incident and was not physically restrained at that point.
- The sergeant learned Coombs had an outstanding arrest warrant for failure to pay fines and arrested and handcuffed her on that warrant.
- At the police station, the sergeant placed Coombs in an interrogation room, administered Miranda warnings, and Coombs indicated she understood her rights and was willing to answer questions.
- The questioning lasted about two to three hours; Coombs was crying and upset, and the sergeant left and re-entered the room during the interrogation.
- For about 15–30 minutes while the sergeant was out of the room, Coombs was handcuffed to a horizontal pole in the interrogation room.
- Coombs ultimately confessed to the theft and signed a written statement after being told she was not required to sign it.
- Coombs claimed the sergeant promised she would not be charged with marijuana possession if she confessed; the sergeant denied making any promises or threats.
- The suppression court credited the sergeant’s testimony, found a voluntary confession and a valid Miranda waiver, and denied suppression; Coombs was later convicted of Class E theft and appealed.

## Issues

1. Whether Coombs’s confession was involuntary under the totality of the circumstances due to coercion, including alleged promises, emotional distress, duration of questioning, and restraint during interrogation.
2. Whether Coombs knowingly, intelligently, and voluntarily waived her Miranda rights before making statements to police.

## Decision

- The Supreme Judicial Court of Maine affirmed the conviction and the denial of the motion to suppress.
- The court held the suppression court did not err in finding the confession voluntary under the totality of the circumstances.
- The court held the State met its burden to show a valid Miranda waiver.
- The court deferred to the suppression court’s credibility findings rejecting Coombs’s claim of an inducement related to marijuana charges.

## Legal Principles

- Voluntariness of a confession is determined by the totality of the circumstances; a confession is inadmissible if the defendant’s will was overborne by coercive state action.
- A Miranda waiver must be knowing, intelligent, and voluntary; the State bears the burden to prove a valid waiver before custodial statements may be used.
- Appellate review defers to the trial court’s supported factual and credibility findings, while applying legal standards to those facts in assessing voluntariness and waiver.
- Emotional distress, extended questioning, and physical restraint do not alone establish involuntariness absent coercive police conduct found to have produced the confession.

## Conclusion

The court upheld admission of Coombs’s stationhouse confession because the suppression court permissibly found no threats or promises, determined her statements were the product of a free choice under the totality of circumstances, and concluded she knowingly and voluntarily waived her Miranda rights.


State v. Coombs, 704 A.2d 387 (Me. 1998)