The Iowa Court of Appeals affirmed the conviction of Cristhian Bahena Rivera, the man sentenced to life in prison for the murder of Mollie Tibbetts, on Wednesday.
Bahena Rivera, who is serving a life sentence at the Iowa State Penitentiary in Fort Madison, appealed his conviction to the Iowa Court of Appeals.
He claimed the district court should have suppressed statements he made to law enforcement and the district court should have granted his motion for a new trial based on newly discovered evidence, according to court documents.
Bahena Rivera claimed he was not properly Mirandized when he spoke with law enforcement before his arrest and immigration detainer. The court determined Bahena Rivera was not in custody and free to leave when he made statements to law enforcement which were later used in court, and he did not need to be read his Miranda rights.
Bahena Rivera motioned after his trial concluded and asked for a new trial citing that he believed that prosecutors had failed to disclose information in a sex trafficking investigation where another inmate admitted to killing Tibbetts.
However, according to the court of appeals, Bahena Rivera’s own lawyers declined to move forward with the inmate’s testimony as it conflicted with their version of events put forth at trial.
Bahena Rivera also argued his confession was involuntary because of the length of his interview and lack of sleep, however, the court of appeals did not find his statements involuntary.
The interview was conducted by a native Spanish speaker and an officer who was deemed proficient in Spanish by the courts. They demonstrated to Bahena Rivera that he was able to leave or use his phone at any time.
Bahena Rivera did not leave the interview, which lasted until around 4 a.m., and during which he admitted to a struggle with Tibbetts. After the interview, he took police to the location of Tibbetts’ body.
The court did determine that the officers failed to properly Mirandize Bahena Rivera at the time of the immigration detainer, therefore, the court omitted Bahena Rivera’s statements made from about 11:30 p.m. until the immigration detainer was in place.
Following the discovery of Tibbetts’ body, Bahena Rivera was read a second set of Miranda rights in Spanish. He acknowledged his understanding and continued to speak with the officers.