Houle v. Allstate Insurance

How later courts describe this case

• despite having mild mental retardation and intelligence quotient of only 70, circumstances surrounding confession demonstrated that defendant possessed “the requisite level of comprehension” to waive his Miranda rights
• testimony by officer that defendant did not make a statement to him at the time of his arrest not a comment on defendant's post-arrest silence because the testimony was `"merely preliminary to the admission into evidence of [Mathenia's] videotaped statement"'
• testimony by officer that defendant did not make a statement to him at the time of his arrest not a comment on defendant's post-arrest *Page 1273 silence because the testimony was " 'merely preliminary to the admission into evidence of [Mathenia's] videotaped statement' "