Whether defendant was entitled to Miranda warnings; Miranda v. Arizona; People v. Burton; Whether the officer’s conversation with defendant was a custodial interrogation; People v. Elliott; People v. Steele

The court held that the trial court did not abuse its discretion by denying defendant’s motion to suppress evidence. He was convicted of operating/maintaining a meth lab and possession of meth after a traffic stop that resulted in a search of his property. On appeal, the court rejected his argument that the evidence gathered from his garage and house should have been suppressed because it was gathered based on a search warrant that was supported by statements he made to the officer during the traffic stop. He claimed that because the officer’s questioning during that stop was a police custodial interrogation, the officer was required to inform him of his Miranda warnings, which he did not do. It found that “a reasonable person would feel free to terminate a general conversation with a police officer, even while waiting on the roadside for their vehicle to be towed.” It then concluded that “defendant was free to terminate the conversation with” the officer, who “stated that he was still conducting an investigation when he asked defendant about meth[] and that he had not made the decision yet to arrest defendant. When considering the location of the questioning, the statements made during the questioning, and the lack of restraints used during the questioning,” defendant’s “freedom of action was not curtailed to a degree associated with formal arrest . . . until he was actually placed in handcuffs and put in” the officer’s vehicle for transport to the jail. As such, “it was not until that point that defendant was entitled to the warnings outlined in Miranda.” Affirmed.