Butler v. State

Stanley Charles Butler, Jr. v. State of Maryland. Case Number 1037, Sept. Term 2021 Opinion by Wells, C.J. CRIMINAL LAW – FIFTH AMENDMENT – SUPPRESSION – DEFENDANT’S BURDEN Even though a private citizen may be deemed an “agent of the State” for the purposes of evaluating an alleged violation of the Fifth Amendment’s protection against self- incrimination, a defendant bears the burden of proving that such a citizen was, in fact, acting as an agent of law enforcement when that person questioned the defendant. Here, Butler failed to demonstrate that an Emergency Medical Technician (EMT), who…