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Quarles v. Commonwealth: Coerced Confessions in Virginia

Jamison KoehlerCriminal Procedure, Opinions/Cases

In Quarles v. Commonwealth, a recently issued opinion by the Virginia Court of Appeals, the court considered a set of facts similar to the U.S. Supreme Court case of Rhode Island v. Innis.  However, finding a number of ways to distinguish this case from Innis, it concluded that the defendant’s confession should have been suppressed as the product of police …