Cleveland v. Oles (Slip Opinion)

Citations

• 2017 Ohio 5834
• 92 N.E.3d 810
• 152 Ohio St. 3d 1

Syllabus

Constitutional law-Fifth Amendment to United States Constitution-Article I, Section 10 of Ohio Constitution-Placement of a suspect in front seat of a police vehicle during a traffic stop does not alone determine whether suspect has been subjected to custodial interrogation such that Miranda warnings were required-Relevant inquiry is whether, under totality of circumstances, a reasonable person in suspect's position would have understood himself to be in custody-Appellee was not subjected to custodial interrogation because intrusion by trooper was minimal, questioning and detention were brief, and interaction was nonthreatening and nonintimidating-Judgment affirming suppression of appellee's statements reversed and cause remanded.