State v. Elkins

Citations

• 2017 Ohio 2725

Syllabus

CRIMINAL LAW - motion to suppress Fifth Amendment Right against self-incrimination defendant's volunteered statements to detective not made in response to an interrogation were properly admitted at trial statements made while hospitalized and suffering from gunshot wound were voluntary and admissible nurse's notes identified defendant as coherent and conscious before statements were made, and detective described defendant as conscious and coherent nothing depicted defendant as confused at the time.