Commonwealth v. Templin

OPINION OF THE COURT

Justice CASTILLE.

This Court granted discretionary pretrial review of a suppression ruling to determine and elucidate the proper standard for evaluating a claim that a confession made after an explicit Miranda 1 waiver was rendered involuntary because it followed upon a promise by police to recommend ROR bail 2 in the event the suspect was arrested and arraigned. The suppression court excluded the confession in this case, focusing exclusively upon the fact of the post-waiver promise, which it deemed an “improper inducement” that “require[d] suppression of the statement.” In…