Earlier this month, a state appellate court issued an opinion in an OWI case involving a fatal car accident. Among the issues raised on appeal, the defendant claimed that a statement he made to a detective while at the hospital should not have been admitted into evidence. However, the court rejected the defendant’s claim, finding that he was not in custody at the time he made the statement and that the police did not act inappropriately when informing him that the victim had died.
The Facts of the Case
According to the court’s opinion, the defendant was driving a white van at about 85 miles per hour in a 55 mile per hour zone when he struck a parked car that had pulled over to assist another motorist. One of the occupants of the vehicle the defendant struck was seriously injured, and the other died.
Police tracked down the defendant, who was found driving the same white van involved in the accident. However, the defendant denied being involved in the accident. The defendant was taken to the hospital for ankle injuries, and while he was there hospital staff took his blood, revealing a blood-alcohol content of more than three-time the legal limit.
While at the hospital, a detective approached the defendant, informing him that one of the people in the car he hit had died. The defendant responded emotionally that he thought he was going to spend the rest of his life in prison. The detective asked if the defendant wanted to make a statement, and the defendant asked for an attorney. The interview then ended.
At trial, the defendant’s statement to the detective was admitted, and the defendant was convicted and sentenced to a lengthy term of incarceration. The defendant appealed, arguing, among other things, that the admission of the statement was improper.
The appellate court rejected the defendant’s argument. First, the court explained that the detective’s actions in truthfully informing the defendant the accident victim had died was not a ploy to overcome the defendant’s will. While some police action may be inappropriate if it is designed to compel a defendant to make a statement, the court found the detective’s actions did not rise to that level.
The court also found that, when the detective approached the defendant, the defendant was not in custody at the time. Thus, there was no requirement that the detective read the defendant his Miranda warnings before speaking to him. Thus, the court affirmed the defendant’s conviction and sentence.
Have You Been Arrested for a Michigan OWI Offense?
If you were recently charged with a Michigan OWI crime, contact Michigan Defense Law for immediate assistance. The dedicated criminal defense lawyers at Michigan Defense Law are committed to fighting for the rights of clients facing serious misdemeanor and felony crimes. They work closely with clients in diligently investigating a case before coming up with a strategic defense. To learn more, and to schedule a free and confidential consultation, call 248-451-2200 today to speak with one of our experienced attorneys.
