Pappaconstantinou v. State

RAKER, Judge.

The question we must consider in this case is whether a confession elicited by a private individual is subject to Maryland’s common law requirement of voluntariness. We shall hold that Maryland’s common law voluntariness requirement does not apply to confessions elicited purely by private individuals.

I

Michael Pappaconstantinou (also known as Pappas) was employed with Auto Row Auto Parts (Auto Row) in Waldorf, Maryland for approximately three years until the company terminated him because it suspected that he had been stealing from the company. Following his termination, Pappas…