The judge presiding over Luigi Mangione’s New York state murder case in the 2024 shooting death of healthcare executive Brian Thompson issued an important pretrial ruling Monday. The mixed decision blocks state prosecutors from presenting certain evidence but allows other key items, such as a gun allegedly used for the fatal shooting as well as a notebook with allegedly incriminating writings.
As for the ruling’s broader implications, it should not stop Manhattan District Attorney Alvin Bragg’s office from making its case against Mangione, who has pleaded not guilty in this case as well as in his separate federal case, where the judge previously rejected his similar suppression motion. Prosecutors must prove the charges beyond a reasonable doubt if the cases go to trial.
Given the high-profile nature of the prosecution and the passion it provokes both for Mangione’s supporters, who have hailed him as a folk hero, and people who think murder is unwarranted no matter the victim’s profession, jury selection will be especially important. The state trial is scheduled to go first, in September.
Monday’s ruling dealt only with the question of what alleged evidence and statements made by Mangione can be presented by state prosecutors to the jury — and what cannot.
Thompson was fatally shot in midtown Manhattan on Dec. 4, 2024, and Mangione was arrested at a McDonald’s in Altoona, Pennsylvania, five days later. Officers first removed some items from his backpack at the McDonald’s and then other items later at the police station.
That distinction of location and type of search was crucial to Judge Gregory Carro’s suppression ruling, because they involved different legal circumstances that called for applying different rules. The backdrop is the Fourth Amendment to the Constitution, which prohibits unreasonable searches and seizures, as well as New York’s state Constitution, which provides even broader protections.
Applying those charters and relevant precedents, the bottom line from Carro’s ruling is that he decided the McDonald’s search was improper while the subsequent search at the station was proper.
Carro wrote that evidence found during the search of Mangione’s backpack at McDonald’s must be suppressed, including a loaded magazine, cellphone, passport, wallet and a computer chip. The judge noted that “exigent” circumstances are required to search closed containers, such as backpacks, when officers make arrests. To invoke that emergency exception, the property must be within the suspect’s “immediate control” or “grabbable area,” and officers must act in furtherance of safety and protecting evidence from destruction or concealment.
But the judge reasoned that the authorities didn’t satisfy those requirements at the McDonald’s, because the backpack wasn’t within Mangione’s immediate control or “grabbable area” at the time of the arrest and search.
Yet, Carro declined to suppress other evidence that was later recovered during an “inventory search” at the station. Such searches, conducted pursuant to police departments’ standardized procedures, are supposed to be done for the purpose of safeguarding property — thus producing a list or “inventory” of property found — rather than searching for evidence of crimes.
Still, if incriminating evidence is discovered during such a properly conducted inventory search, then that evidence can be used at trial. Because the gun and notebook were recovered pursuant to what the judge found was that subsequent, proper process, prosecutors will have that important evidence available to use against Mangione at trial.
The implication from the ruling is that if law enforcement had first obtained a warrant or only removed items pursuant to an inventory search, then all the evidence would be admissible at Mangione’s state trial. Carro added that a search warrant for the backpack obtained later — after both searches — doesn’t retroactively make the tainted evidence admissible, because doing so in this case would negate the warrant requirement.
In that same decision, the judge also issued a mixed ruling on the admissibility of various statements allegedly made by Mangione.
Carro distinguished between allowing statements that the defendant allegedly made at McDonald’s when he wasn’t legally “in custody” and disallowing statements allegedly made when he was. The judge found that Mangione wasn’t in custody when “only” two or three officers were there but that he was in custody after more than eight officers arrived and “positioned themselves in a manner that effectively encircled the defendant and controlled the immediate area, creating a police-dominated atmosphere.”
The judge therefore suppressed statements, including Mangione’s alleged responses to officers’ questions when they asked why he lied about his name and whether he had a fake ID. But the judge declined to suppress answers to officers’ questions about his real name and related biographical information.
Finally, Carro wrote that he’s allowing statements Mangione allegedly made to Pennsylvania correctional officers who were monitoring him, with the judge reasoning that the defendant made those statements without those officers questioning him or trying to get information out of him. Among those alleged statements are ones Mangione made to an officer about the healthcare system and people appearing to be happier in “Third World countries” and that he “wanted to make a statement to the public.”
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