Jamie Aaron Kuhne v. Commonwealth of Virginia

McCullough, judge.

Jamie Aaron Kuhne challenges his voluntary manslaughter conviction, arguing that certain statements he made to law enforcement should have been excluded as the fruit of an illegal interrogation under Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966), and Missouri v. Seibert, 542 U.S. 600, 124 S.Ct. 2601, 159 L.Ed.2d 643 (2004). We assume, without deciding, that appellant was in custody, and we hold that the statements were admissible under Seibert. We, therefore, affirm the judgment of the trial court.

BACKGROUND

On December 11, 2009, around 7:20 a.m.,…