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People v. Roark: Court of Appeals Makes Ruling on Miranda and Custodial Environment

September 1, 2015 Criminal Law and Procedure

The Court of Appeals discussed custodial interrogation in regards to Miranda warnings in the case of People v. Roark.

The Defendant in this case was convicted after a jury trial of possession of cocaine, less than 25 grams. The Defendant appealed her conviction.

Prior to trial, Defendant had filed a motion to suppress statements made to police. On appeal, the Defendant argued the trial court should have granted this motion because the statements were made without advice of rights required by Miranda.

In this case, the Defendant was in a car accident and was unable to show a driver’s license. Her license had been suspended. The investigating officers decided to perform a check for any past warrants. While the officers made that check, the Defendant was told to sit in the back of the police car. The officer told Defendant she would have to post a bond because there were outstanding warrants. While the Defendant was going through her purse for the bond money, the officer decided to perform a search of the purse. A search revealed a little cocaine.

While in the backseat of the police car, the officer questioned Defendant and elicited incriminating statements.

The Defendant made a motion to suppress these statements in trial court. The court ruled that Defendant was not in custody because Defendant had been told she would be free to leave. Therefore, the court ruled, the officer was not obligated to give Miranda.

Michigan case law has ruled that Miranda must be given when a person is in custody or otherwise deprived of freedom of action in any significant manner. The courts use a totality of the circumstances to determine if a person is in custody. The main question is whether the person reasonably could have believed that he was not free to leave.

The Court ruled here that under the totality of the circumstances a reasonable person would not believe he was free to leave until such time as bond was posted and the officer released him. The Court went on to say that, “the fact that Defendant was aware that she would be released at some point in the future does not alter the fact that, until that release occurred, she was in custody.” In addition, the Court said there is no exception to Miranda where a suspect is informed he will eventually be released.

What is a Miranda Warning?

A Miranda warning is something we’ve all probably heard on television or in the movies. It usually goes, “you have the right to remain silent, you have the right to an attorney, anything you say can and will be used against you in a court of law.” The warning serves as a safeguard against false confessions, as well as prevents coercion by police.

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