State of Tennessee v. Raffael Fansano

The Defendant, Raffael Fansano, was indicted for aggravated rape. The Defendant filed a motion to suppress his confession, arguing, among other things, that he did not knowingly and voluntarily waive his Miranda rights due to his intellectual disability. The trial court granted the Defendant’s motion to suppress, and the State sought and was granted an interlocutory appeal of the trial court’s decision. On appeal, the State contends that the Defendant was not in custody when he made the statement at the police department and, alternatively, that the trial court erred when it determined that the Defendant did not knowingly and voluntarily waive his Miranda rights. Following our review, we affirm the judgment of the trial court.