State v. Elliott

Citations

• 2023 Ohio 388

Syllabus

The trial court correctly overruled appellant's motion to suppress a confession he made to a detective and pictures the detective obtained from his cell phone. The protections of Miranda did not apply when appellant made his confession and the detective discovered the pictures, because appellant's interaction with the detective was not a custodial interrogation. Appellant's confession to the detective also was voluntary and not a product of police coercion. Judgment affirmed.