In re C.M.R.

Citations

• 2018 Ohio 110
• 107 N.E.3d 34

Syllabus

The trial court did not err in overruling a motion to suppress filed by Appellant, a juvenile, challenging the statements he made while being interviewed by an investigating detective. Appellant's statements were not made while he was in custody therefore, the investigating detective was not required to advise Appellant of his Miranda rights. In addition, because Appellant was not in custody, Appellant had no Fifth Amendment right to counsel, which he otherwise did not invoke, nor were Appellant's statements involuntarily induced by coercive police conduct. Furthermore, at the time of Appellant's interview with the investigating detective, no complaint had been filed against him and he had not made an initial appearance at juvenile court accordingly, Appellant did not have a statutory right to counsel under R.C. 2151.352 or a constitutional right to counsel under the due process clause of the Fourteenth Amendment. Lastly, Appellant's adjudication for rape was supported by sufficient evidence and was not against the manifest weight of the evidence. Affirmed.