State v. King

After a jury trial, Defendant was convicted of criminal threatening. Before trial, Defendant filed a motion to suppress statements he had made after police officers stopped his vehicle, took his license and registration, and asked him to wait for a detective to arrive. The suppression court granted the motion in part but denied it as to the statements Defendant made before he was placed in handcuffs and arrested, holding that Defendant was not in custody until he was placed in handcuffs and that after he was handcuffed he did not waive his Miranda rights. Defendant appealed, arguing that the trial court erred by declining to suppress the statements that he made to the detective before his formal arrest. The Supreme Court vacated the judgment of conviction and vacated the suppression order in part, holding that Defendant was in custody when he responded to the detective’s questions and accusations, and because he was in custody when he made incriminating statements without the benefit of Miranda warnings, those statements were improperly admitted at trial. Remanded. View "State v. King" on Justia Law