Poulson v. Commonwealth

Syllabus

04/10/2025 The arguments of a driving-under-the-influence defendant that he should have been given Miranda warnings during events transpiring within the curtilage of his home, and that officers should have obtained a warrant before he was arrested on that curtilage, are rejected. Miranda warnings were not required, as those safeguards are afforded to a suspect as soon as the police have restricted his freedom of action to a degree associated with formal arrest, and the Fourth Amendment does not proscribe voluntary cooperation. It is also concluded, in accord with the overwhelming weight of authority, that when the officers are lawfully present in the home or on the curtilage, and the arrest is otherwise proper, they may proceed to effect an arrest without the additional step of obtaining an arrest warrant. Finding no error, we affirm the judgment of the Court of Appeals.