April 19, 2012
First, the grisly facts.
In November 2009, police were called to Melissa Engelhardt’s residence after it was reported that her 21-month-old stepson was found dead in his playpen.
Engelhardt initially told police that when the infant arrived at her home on the day prior to his death, he was tired and had no appetite, but nothing unusual had occurred and it appeared to her that his death was the result of natural causes.
Through the subsequent investigation, though, it was determined that the child’s death was actually caused by methanol poisoning and that traces of methanol were found on his drinking cup.
During the police investigation, the police, with Engelhardt’s consent, took a computer from her home, conducted a forensic examination on its hard drive, and determined that someone had done an Internet search on poisoning shortly before the child’s death.
After this, the police again contacted Engelhardt, but she refused to submit to any additional questioning about the child’s death, and further stated that her mother had told her that she was represented by Legal Aid.
The next day, Engelhardt telephoned the detective in charge of the investigation, stated that she actually wasn’t represented by an attorney, and that she was willing to go to police headquarters to answer additional questions concerning her stepson’s death.
When she arrived at police headquarters, Engelhardt was advised of her Miranda rights, but waived them, and the police proceeded to interview her.
During the interview that followed, Engelhardt ultimately admitted to police that she had laced her stepson’s apple juice with windshield washer fluid shortly before he drank it on the night prior to his death.
Based on this admission and other evidence developed by the police during their investigation, Engelhardt was arrested and was later charged with murder in the second degree and manslaughter in the first degree.
Engelhardt waived her right to a jury trial (probably because, given the facts, her chances of success with a jury would have been extremely slim), and, after a bench trial, the Chemung County court in New York state acquitted her of murder, but found her guilty of manslaughter in the first degree.
Engelhardt appealed for two reasons.
First, she argued that the court erred in denying her motion to suppress her admission because she was in police custody at the time, and had exercised her right to counsel.
Second, she argued that her sentence – 20 years in prison and five years of postrelease supervision – was harsh and excessive.
The New York appeals court affirmed the lower court, and rightfully so.
Hot Doc: People v. Engelhardt
First, Engelhardt voluntarily came down to police headquarters to discuss what happened.
While she was there, the police immediately advised her of her Miranda rights, which she waived.
Engelhardt was allowed to leave the interview room to speak with her mother, who had accompanied her to the police station, and, more significantly, Engelhardt left the station with her mother for 40 minutes to get some food.
The admission came out of Engelhardt after she returned to the police station after lunch, and after the police had again advised her of her Miranda rights.
This isn’t a tough question.
It’s pretty obvious that Engelhardt wasn’t being held in police custody at the time that she made those statements – she voluntarily went down to the police station, voluntarily stayed there, and volunteered the information about her stepson’s death.
On the second issue – that of the “harsh” sentence – Engelhardt didn’t even receive the maximum sentence.
The appeals court further noted the circumstances of the crime: Engelhardt was criminally responsible for the death of a 21-month-old child who had been entrusted to her care.
Engelhardt should consider herself lucky that she got off as easy as she did, because it’s almost a sure bet that a jury wouldn’t have acquitted her of the second degree murder charge.
Thanks to this ruling, though, Engelhardt will have 20 years’ time to contemplate her good fortune.