Recently, a state appellate court issued a written opinion in a Michigan OWI case requiring the court to determine whether statements the defendant made before and after his arrest should have been excluded from the jury’s consideration. While the court determined the trial judge should have suppressed certain statements, the court held that the remaining statements were admissible. Thus, the court affirmed the defendant’s conviction and sentence.
The Facts of the Case
According to the court’s opinion, the case involved a man who allegedly pulled out into traffic while operating a car under the influence of methamphetamine and marijuana. He had four children in the car at the time. When police officers arrived at the scene of the accident, they immediately started asking the defendant questions. The defendant admitted to smoking marijuana two hours before the accident.
Upon further investigation, police arrested the defendant, although they did not read him his Miranda rights. Police searched the car and found methamphetamine and marijuana. They then continued to question him. Although the court’s opinion does not specify the nature of the defendant’s answers, it is fair to assume that they were not favorable.
In a pre-trial motion to suppress, the defendant challenged the admissibility of his post-arrest statements. The trial court denied the defendant’s motion, and he was ultimately convicted.
On appeal, the defendant again challenged the admission of his post-arrest statements but also argued that the statements he made to police officers before he was arrested should be suppressed.
Generally, the state and federal constitutions require a person to be provided their Miranda warnings when they are under “custodial interrogation.” While there is no exact definition of what constitutes custodial interrogation, questioning outside the context of official police detention does not generally require police to read a suspect their Miranda rights.
Here, the court determined that any statements the defendant made after he was in handcuffs should have been suppressed because, at that point, he was subject to custodial interrogation. However, the court also held that the pre-arrest questioning regarding the defendant’s marijuana use did not implicate Miranda because the defendant was neither in custody nor a suspect at that time. The court explained that, although the police officers had found marijuana on the defendant, this did not necessarily mean he was under investigation for operating while intoxicated or any other crime.
Have You Been Arrested for a Michigan Drunk Driving Offense?
If you are facing Michigan OWI charges after getting into a car accident, reach out to Michigan Defense Law for immediate assistance. While penalties for OWI are severe on their own, they increase dramatically if someone was injured in an accident. At Michigan Defense Law, our dedicated criminal defense lawyers aggressively defend your rights at every stage of the process. We also recognize the stress that comes along with having an open criminal case, and do everything we can to put your mind at ease. To learn more, and to schedule a free consultation, contact us at 248-451-2200. You can also reach us through our online contact form.
