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Keywords

willmisdemeanorinterrogationrespondentadmissibility

appealfelonymisdemeanorinterrogationrespondent

Related Cases

Berkemer v. McCarty, 468 U.S. 420, 104 S.Ct. 3138, 82 L.Ed.2d 317

Facts

On March 31, 1980, Trooper Williams of the Ohio State Highway Patrol observed the respondent's car weaving on the highway and initiated a traffic stop. After noticing the respondent's difficulty standing, the officer concluded that he would be charged with a traffic offense but did not inform him he was in custody. Following a failed field sobriety test, the respondent admitted to consuming alcohol and marijuana before being formally arrested and taken to jail, where he made further incriminating statements without being given Miranda warnings.

After observing respondent's car weaving in and out of a highway lane, an officer of the Ohio State Highway Patrol forced respondent to stop and asked him to get out of the car. Upon noticing that respondent was having difficulty standing, the officer concluded that respondent would be charged with a traffic offense and would not be allowed to leave the scene, but respondent was not told that he would be taken into custody.

Issue

Does the Miranda v. Arizona decision govern the admissibility of statements made during custodial interrogation by a suspect accused of a misdemeanor traffic offense, and does roadside questioning of a motorist constitute custodial interrogation?

The parties have stipulated to the essential facts.

Rule

A person subjected to custodial interrogation is entitled to the procedural safeguards enunciated in Miranda, regardless of the nature or severity of the offense for which he is arrested.

A person subjected to custodial interrogation is entitled to the benefit of the procedural safeguards enunciated in Miranda, regardless of the nature or severity of the offense of which he is suspected or for which he was arrested.

Analysis

The Court determined that the motorist was 'in custody' at the moment he was formally arrested and thus entitled to Miranda warnings. The roadside questioning did not constitute custodial interrogation, as it was brief and conducted in public, allowing the motorist to expect he would likely be allowed to leave. However, the lack of warnings before the formal arrest rendered the subsequent statements inadmissible.

In this case, the initial stop of respondent's car, by itself, did not render him 'in custody,' and respondent has failed to demonstrate that, at any time between the stop and the arrest, he was subjected to restraints comparable to those associated with a formal arrest.

Conclusion

The Supreme Court affirmed the appellate court's decision, ruling that the motorist's postarrest statements were inadmissible due to the failure to provide Miranda warnings.

The implication of this holding is that the Court of Appeals was correct in ruling that the statements made by respondent at the County Jail were inadmissible.

Who won?

The respondent prevailed because the Supreme Court ruled that his statements made after formal arrest were inadmissible due to the lack of Miranda warnings.

A divided panel of the Court of Appeals for the Sixth Circuit reversed, holding that 'Miranda warnings must be given to all individuals prior to custodial interrogation, whether the offense investigated be a felony or a misdemeanor traffic offense.'

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