NY State Court of Appeals unanimously upholds Scott Doll's murder conviction
|Mug shot of Scott Doll the morning of his arrest.|
Today the New York State Court of Appeals unanimously upheld the murder conviction of Scott Doll.
A jury found him guilty on May 20, 2010 of killing Joseph Benaquist, a fellow former corrections officer and business partner.
The main consideration of the appellate judges was whether the police took appropriate action under what's known as the emergency doctrine in detaining Doll without reading him his Miranda warnings and initially interviewing him without an attorney present. Law enforcement's response "to a serious and ongoing exigent situation under the emergency doctrine" was deemed reasonable.
In the ruling by the seven justices, the circumstances of the case were recapped:
On Feb. 16, 2009, Genesee County Sheriff's Deputy James Diehl responded to a report of a suspicious person walking on Lake Road in Pembroke and he found a man wearing a camouflage hunting outfit and a white hood. The man dropped a metal object and pulled a lug wrench from his pocket and the officer saw what appeared to be wet blood stains on the man's knees, thighs, hands and shoes.
When asked, the man produced a correction officer identity card with his name on it -- Scott Doll, who proceeded to say he was out walking to lower his blood pressure because he had a doctor's appointment the next day. He asked for a ride to his van at a car lot and the deputy agreed to take him there.
Once inside the patrol car, the firefighter who initially placed the 9-1-1 call came to the scene and told the officer that he'd noticed the defendant at the lot and the guy turned away and crouched between two cars to try and hide. Based on this information, the deputy told the defendant he was being detained until the situation was assessed. Doll was frisked and handcuffed.
When asked about the blood on his clothes, Doll said his was wearing his camouflage outfit because it was cold, but didn't explain why the clothes had wet blood on them. The deputy drove Doll to his van and discovered blood in several places inside and outside the van and bloody gloves nearby.
Soon other police officers arrived and noticed blood on Doll's face and noticed he left bloody footprints in the snow. Around this time Doll asked to speak to his divorce attorney. He was then questioned about whether the blood was from a deer or a human, Doll declined to explain the source of the blood or to take the officers to an alleged butchered deer.
Judge J. Gaffeo wrote: "These unusual circumstances caused the deputies to believe that a person may have been injured in an accident or assault so they continued to question (the) defendant despite his request for legal assistance."
Doll repeatedly told officers he couldn't answer their questions and police tried contacting his family and acquaintances to determine whether anyone needed emergency aid. Officers also searched the area for an injured person. Eventually, they went to the defendant's business partner's house and discovered Benaquist bludgeoned to death in his driveway. In the meantime, police impounded Doll's van and took him to the Sheriff's Office, where he was photographed, DNA tested, and his clothes seized.
Hours later, a friend and former coworker asked to speak with Doll. An investigator, who was aware of the business partner's demise, initially rebuffed the visitor. Then the investigator relented and said he would be staying in the room and taking notes.
Doll told the woman that the case didn't involve an animal; he had been present but didn't do anything; the case was "open and shut"; he would be going to jail and probably get what he deserved.
The investigation, indictment for second-degree murder and prosecution followed.
Doll's attorney, Paul Cambria, moved to suppress statements made to police and to his female friend, as well as all the physical evidence, primarily claiming his client had been arrested without probable cause, interrogated in violation of his right to counsel and without receiving his Miranda warnings.
Genesee County Court conducted an evidentiary hearing and ruled the detention and questioning of the defendant were justified under the emergency doctrine. However, County Court did suppress the defendant's DNA test results because the police could've obtained a warrant.
A jury subsequently convicted Doll of second-degree murder and he was sentenced to a prison term of 15 years to life. That conviction was appealed and in 2012 the Appellate Division majority determined the police actions were reasonable in this emergency situation. Two justices dissented, saying the emergency doctrine was not applicable since the police didn't know whether an actual crime victim existed.
The dissension allowed Doll's attorney to then appeal to the New York Court of Appeals. The justices agreed that police properly relied on the emergency doctrine in light of the "peculiar circumstances" they were confronted with because "...the emergency doctrine is premised on reasonableness, not certitude."
As to the defense seeking to suppress statements Doll made to his friend at the Sheriff's Office, saying it amounted to the police using the woman to conduct the functional equivalent of a custodial interrogation, the Court of Appeals disagreed. Its ruling states the purpose of the Miranda rule is to prevent government officials from "using the coercive nature of confinement to extract confessions that would not be given in an unrestrained environment." As a matter of law, Doll's conversation with his friend did not constitute an interrogation.
Finally, as to Doll's challenge of the legality of his detention by police, the panel ruled it had no merit.