In re S.W.

Citations

• 2022 Ohio 854

Syllabus

MOTION TO SUPPRESS – JUVENILE – MIRANDA – INTERROGATION – SPONTANEOUS STATEMENT: The juvenile court erred by suppressing a statement made by juvenile in police custody because the statement was spontaneous and was not made in response to interrogation the statement was neither triggered by an express question nor its functional equivalent where the juvenile was not subjected to words or actions that the officer should have known were reasonably likely to elicit an incriminating response. [But see DISSENT: Where the issue of whether an interrogation is on-going is a factual matter, and the juvenile court's findings of fact are supported by competent, credible evidence, the juvenile court did not err in granting the motion to suppress.]