Facts
In 1988, John Pruitt confessed to the murder of Joan Easterling, a Pass Christian resident. Pruitt first confessed his involvement during a conversation (initiated by Pruitt) with Kenneth Bangs, a jailer with the Harrison County Sheriffs Department. According to Bangs, Pruitt then asked to speak with Detective Thomas Ruspoli of the Pass Christian Police Department. Bangs wrote a narrative detailing his conversation with Pruitt which reads as follows:
On date listed above at approximately 17:45, I, Deputy Bangs, was making my usual cell check when above subject stopped me, John Pruitt, and stated he had something to get off his chest. I asked what, and above subject stated he killed a lady by hitting her in the head with a hammer. I asked her name. Above subject stated her name was Joan, but was not sure of her last name. Then I asked above subject, where did he kill her. Above subject then stated, in her house in Pass Christian. Above subject then stated he broke into a house and stole a gun that he was going to use to kill his ex-wife.
Later, Pruitt was interviewed by Detective Ruspoli and after receiving Miranda warnings, Pruitt again confessed to the killing. According to this statement, an intoxicated Pruitt persuaded Easterling to let him into the house by claiming that Nell Deronja (Pruitt’s aunt and the owner of the home Easterling was renting) sent him to fix a leaking water pipe.
Once inside, Pruitt first pulled a knife on Easterling. She then began screaming, and Pruitt panicked and began beating her with a ballpeen hammer he found lying on a cabinet. After killing Easterling, Pruitt tried to arrange her clothes so that it would appear to have been a rape.
Pruitt admitted that his true purpose in entering the home was to rob Easterling because he “needed some money.” He then left the home and threw his bloody clothes into a canal. At the time of Pruitt’s statement to Detective Ruspoli, Pruitt said that he felt slightly intoxicated, but clearly admitted to his involvement in the crime. Pruitt’s clothes were later recovered from the area where he claimed to have disposed of them.
Pruitt had been arrested earlier on the afternoon of his confession on charges of possession of a firearm by a convicted felon, and at the time of his arrest, he was in a Gulfport bar where he had drunk several beers.
At trial, Pruitt moved to suppress his confession on the grounds that it was involuntary due to intoxication. However, several witnesses testified that he did not appear to be intoxicated at the time of his confession. Ultimately, the trial court concluded that the level of detail in Pruitt’s responses combined with the number of witnesses who said he did not appear to be intoxicated at the time of his confession indicated that, assuming Pruitt was intoxicated at all, he was not so intoxicated as to render his confession involuntary.
Pruitt himself was the only defense witness called, and he denied killing Easterling, claiming that his confession was a result of his intoxication and intimidation by police officers who threatened him with the death penalty. In rebuttal, Detective Ruspoli denied threatening Pruitt with the death penalty and denied telling him what to say. The State also pointed out in its cross-examination of Pruitt that his eleven-page confession was very detailed and that he would have had less than 20 minutes to memorize the information contained within it, if he had been coached by police at a time when he claimed to have been too intoxicated to know what he was doing.
Pruitt was convicted of murder and sentenced to life. On appeal, he argued he was too intoxicated to give a statement. MSC affirmed.
Analysis
At trial, Pruitt claimed that he was coerced into confessing by threats that he would receive the death penalty if he did not. He has abandoned this claim on appeal and now alleges only that his confession was involuntary due to his intoxication and that his free will was overcome by the suggestion of Deputy Bangs that it would go better for him if he confessed. Pruitt also cites his eighth-grade education as a factor the trial court should have considered in suppressing his confessions, although he cites no authority for that proposition.
In O’Halloran, we said that intoxication does not automatically render a confession involuntary. The admissibility of a confession depends upon the degree of intoxication.
The record reflects evidence that Pruitt had been drinking on the morning of his arrest, and he claimed to have been drinking heavily the night before. Pruitt said in his confession to Detective Ruspoli that his arrest took place at about 1:00 in the afternoon, but his first confession to Deputy Bangs did not take place until 5:45 that night, and his second confession to Detective Ruspoli did not take place until later at 8:10 that night.
Furthermore, Deputy Bangs, Detective Ruspoli, and several other witnesses all testified that Pruitt did not appear to be intoxicated at the time of his confessions. Finally, Deputy Bangs categorically denied making any coercive statements to Pruitt that it would go better for him if he confessed.
In sum, Pruitt has failed to show that the trial court’s findings regarding the voluntariness of his confessions were clearly against the overwhelming weight of the evidence. This issue is without merit.