Knight v. State

These two otherwise unconnected cases, Sirbaugh v. State, No. 94, September Term 2003, and Knight v. State, No. 93, September Term 2003, each present the question of whether an interrogating officer’s assumedly truthful promise to a criminal suspect to report to the prosecuting authority that the suspect cooperated with an investigation is an improper inducement that renders a subsequent statement by that suspect involuntary under Maryland non-constitutional law and, therefore, inadmissible at trial.

Petitioner Steven Daniel Sirbaugh was told by police officers that if he cooperated during a…