State v. Olan

Citations

• 2024 Ohio 1257

Syllabus

MOTION TO SUPPRESS – CUSTODIAL INTERROGATION – MIRANDA: The trial court did not err by denying defendant's motion to suppress his statements on the grounds that he was not advised of his Miranda rights because the questioning occurred during an investigative detention after a traffic violation and not a custodial interrogation. [See CONCURRENCE: Considering, in full, defendant's arguments regarding his passport and the entire length of the body-camera video admitted into evidence, custody is a closer call, but the trial court did not err in denying defendant's motion to suppress.] [But see DISSENT: Under the totality of the circumstances, a reasonable person in defendant's position would have understood himself to be in custody where defendant was blocked in by three police cars with their lights on and questioned about matters unrelated to the traffic stop, defendant's passport was not returned prior to questioning, a language barrier was present between defendant and the officers, and defendant's passenger was arrested.]