State v. Laster

Citations

• 2018 Ohio 3601

Syllabus

Any error in the certificate of assignment of a visiting judge was voidable, not void. Nonetheless, Appellant waived this procedural error and there is no reason to notice plain error. The trial court also did not err in overruling Appellant's motion to suppress evidence. When Appellant was detained and questioned, he was not in custody and the police were not required to administer Miranda warnings. Further, since Appellant's statements were not obtained during custodial interrogation, statements that he later made after being given Miranda warnings were admissible. Finally, Appellant waived any error with respect to the reliability of an anonymous tip, as he failed to raise the issue in the trial court, and there is no plain error concerning this point. Judgment affirmed.