State of Alaska v. Steven Ridenour

Summary

The Alaska Supreme Court adopted a "stop and clarify" rule under article I, sections 9 and 11 of the Alaska Constitution: when a suspect who has waived Miranda rights later makes an ambiguous request for counsel, interrogating officers must stop questioning and clarify whether the suspect is requesting a lawyer. Applying that rule, the court held the troopers never asked whether Ridenour wanted a lawyer, addressed only his right to remain silent, and implied exculpatory evidence might be lost without his cooperation, so his post-request statements should have been suppressed. The court confirmed that under the Fifth Amendment (Davis) no stop-and-clarify duty exists and Ridenour's federal rights were not violated, and it affirmed the court of appeals' reversal of his convictions.