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KIDD v. STATE

No. 45, September Term, 1976.

33 Md. App. 445 (1976)

366 A.2d 761

BRUCE D. KIDD v. STATE OF MARYLAND.

Court of Special Appeals of Maryland.

Decided November 3, 1976.

Attorney(s) appearing for the Case

Harriette Cohen, Assistant Public Defender, with whom was Alan H. Murrell, Public Defender, on the brief, for appellant.

Deborah K. Handel, Assistant Attorney General, with whom were Francis B. Burch, Attorney General, William A. Swisher, State's Attorney for Baltimore City, and Wayne Cymek, Assistant State's Attorney for Baltimore City, on the brief, for appellee.

The cause was argued before MOYLAN, MENCHINE and LOWE, JJ.

MOYLAN, J., delivered the opinion of the Court.

The root problem giving rise to the present appeal is the failure to appreciate that in 1966 the warning and waiver requirements mandated by Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694, did not supersede preexisting constitutional law on the admissibility of confessions; the requirements of Miranda simply superimposed additional criteria for admissibility...

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