U.S. Supreme Court Reinstates Murder Conviction of Archie Dixon

The U.S. Supreme Court has made a significant decision reinstating the murder conviction and death sentence of Archie Dixon, who was found guilty in the 1993 "buried alive" death of Christopher Hammer. In a reversal of a lower court's decision, the high court overturned a 2010 ruling by the 6th U.S. Circuit Court of Appeals that had thrown out Dixon's conviction and ordered a new trial. The appeals court had determined that Dixon's confession to the crime was tainted because police started questioning him about a forgery charge without informing him of his Miranda rights.

Key Takeaways:

The U.S. Supreme Court ruled that there is no evidence that Archie Dixon's statements were the product of actual coercion, despite police not giving him Miranda warnings before his first interrogation.
The Supreme Court noted that the Ohio courts recognized the failure of detectives to give Dixon Miranda warnings and imposed the appropriate remedy: exclusion of Dixon's forgery confession and attendant statements given without the benefit of Miranda warnings.
Archie Dixon was initially arrested for forgery, not murder, in connection with the disappearance of his former roommate, Christopher Hammer.
Dixon was encouraged to strike a deal with law enforcement officials in exchange for a reduced sentence, but no deal was ever reached.
The U.S. Supreme Court has never held that there was anything improper about encouraging a suspect to strike a deal before a conspirator could be apprehended.
Archie Dixon and his accomplice, Timothy Hoffner, were convicted of aggravated murder, kidnapping, aggravated robbery, and forgery.
The gruesome murder involved burying Hammer alive in a shallow grave in Sylvania Township.

Statistics:

Archie Dixon, 37, and Timothy Hoffner, 39, are currently on death row at Ohio State Penitentiary in Youngstown.
The body of Christopher Hammer was found in a shallow grave in Sylvania Township soon after his disappearance in 1993.
A third person, Kristen Wilkerson, Dixon's girlfriend, was convicted of kidnapping but was later released from prison after cooperating with police in the case.

Sources:

Jim Provance, "U.S. High Court Reinstates Murder Conviction", The Blade (Toledo, Ohio), November 7, 2011.
The Blade (Toledo, Ohio) at www.toledoblade.com
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