The Dangers of Making Promises to Suspects Introduction . Last year, in a decision called Beavers v. State , the Alaska Supreme Court said that threats are worse than promises and that threats will almost always make a confession involuntary. But two recent decisions by the Alaska Court of Appeals highlight the dangers of making promises. In Miller v. State , the court held that a promise of immunity made the defendant s confession inadmissible. In Moradilla v. State , the court held that a promise of leniency made the defendant s confession too unreliable to support a search warrant.
Promises can make confessions invalid.
In Miller , the defendant was questioned by police about a fire at a nearby warehouse. The defendant then told the police that he had started the fire accidentally. He subsequently was convicted of arson, on the theory that he had recklessly or negligently set the warehouse on fire. The court of appeals reversed his conviction. Miller v. State, P.2d, Op.