State v. Cottrell

Citations

• 2019 Ohio 889

Syllabus

The trial court erred by suppressing Appellant's incriminating statements and physical evidence on the basis that the statements were involuntary. The evidence does not support finding that the detective made false promises or that the statements were involuntary. Nothing the detective said overbore Appellant's will to resist and critically impaired his capacity for self-determination. The physical evidence was not obtained after custodial interrogation without Miranda warnings. Cottrell was not in custody, so Miranda warnings were not necessary. Reversed and remanded. (Donovan, J., dissenting.)