Secret v. Commonwealth: The Virginia Supreme Court Imposes Due Process Limitations Upon Two-Step Pol

On October 11, 2018, the Virginia Supreme Court unanimously decided Nicholas Charles Secret v. Commonwealth of Virginia, 2018 Va. LEXIS 136 (Record No. 170540). Justice Elizabeth A. McClanahan authored the Court’s to-be-published opinion. The decision affirmed Secret’s convictions for arson of an occupied structure and nine counts of attempted first-degree murder. As a question of first impression, the Court addressed and imposed due process limitations upon the police tactic known as a “two-step” interrogation, or sometimes called a “question first” police strategy. The Court also resolved Secret’s sufficiency of the evidence challenge to his attempted first-degree murder convictions. Sec

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