What would Jerry Springer say?
Davis went out drinking, and when he came home his girlfriend and their daughter were missing. He called his girlfriend's mother (Jody) a couple times and asked her to go find them. She couldn't find them, so she came over to Davis' apartment and talked to him about his commitment to Stacey (Davis' girlfriend). That led to an argument, and Davis made some comment about Jody's husband's affair, but apparently felt bad about the low blow because he tried to comfort her afterwards. Then Davis and Jody had sex, and got into another argument. This argument was apparently more serious, Jody cut Davis with a knife and he tried to strangle her and then stabbed repeatedly. He wrapped her up in a sheet to keep her alive, but she died, so he went to sleep. When he woke up, he panicked, stole her car, and fled. Oh, he was still drunk so he crashed the car and wound in the hospital and under arrest for DUI. Meanwhile, Stacey got home and found her dead mother, called the police, and the police put two and two together....
So the police interrogated Davis at the hospital (after obtaining a Miranda waiver). He made some incriminating statements, and he was eventually convicted of murder and sentenced to death. He appealed. The Oklahoma Criminal Court of Appeals affirmed his conviction, and the appeals eventually led to the Tenth Circuit reviewing the Oklahoma court's reasoning to decide whether or not he could proceed with further appeals.
Most of the issues reviewed aren't really important to cops (things like ineffective assistance of counsel, sufficiency of evidence for a conviction, and whether or not Stacey should have been allowed to testify). The important stuff is all Miranda related.
In order for a Miranda waiver to be valid, it must be made knowingly and voluntarily. In other words, a suspect has to understand the nature of the rights being waived, and has to make a free and deliberate choice to waive the right (free from coercion, intimidation, or deception).
Davis argued that because of the morphine he was on at the hospital during his first interrogation, he was incapable of understanding his rights. But the evidence showed that he was having a pretty lucid back-and-forth discussion with the officers, so the Oklahoma court held that he was obviously capable of understanding. The Tenth Circuit agreed. During a follow-up interview, the police informed Davis that the evidence indicated he was the killer, and suggested that there were two logical conclusions. Option A was that Davis was a cold-blooded killer, option B was he didn't mean to kill Jody but a fight broke out and it just happened. Davis chose option B, but argued in court that the police were coercing him into confessing by calling him a cold-blooded killer. The Oklahoma court found that the statement wasn't threatening or coercive, and the Tenth agreed again. Finally, Davis argued that the police coerced him by denying him painkillers, but that argument was plainly refuted by the facts of the case and none of the courts were willing to listen to it.
The rest of this decision is more important for prosecutors. To sum of the important parts above: if a suspect seems lucid, that's an indicator of his ability to understand his rights. Also, the interrogation tactic of presenting alternate theories of guilt (including one which is easier to admit to) is still something that the courts are okay with.
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