Adrienne Johnson v. United States, 207 A.3d 606

On May 14, 2017, Adrienne Johnson struck her 13-year-old son A.J. repeatedly with a wooden stick about the thickness of a broomstick; the stick broke and she continued striking with the pieces, producing bruises and a mark behind his left ear.
The next day CFSA followed up; Johnson acknowledged she disciplined A.J. for taking a tablet from her room.
Metropolitan Police detectives and CFSA workers interviewed Johnson at her home; Detective Williams-Thomas (uniform not worn, service weapon concealed) questioned Johnson in the living room for ~30 minutes; Detective Mackinoff was outside near the front door.
Johnson was charged with two counts each of attempted second-degree cruelty to children and attempted possession of a prohibited weapon (PPW) — one set involving the stick and one involving a belt.
Johnson moved to suppress her statements, arguing custodial interrogation without Miranda warnings; the trial court denied suppression, convicted her of attempted second-degree cruelty to children and attempted PPW as to the stick, and acquitted on counts involving the belt.
On appeal the D.C. Court of Appeals affirmed, rejecting the Miranda claim and finding the evidence sufficient to prove excessive parental force and that the stick was a dangerous weapon as used.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Johnson was in custody for Miranda purposes when questioned at home	Johnson: Interview was custodial because detectives were armed, she wasn’t told she could leave, and presence near the door suggested she could not leave	Government: Interview was noncustodial; conversational tone in familiar surroundings, no restraints or brandished weapon	Held: Not custodial — totality showed no restraint comparable to formal arrest; no Miranda violation
Whether evidence was sufficient to convict of second-degree cruelty to children given parental-discipline privilege	Johnson: Force was disciplinary and privileged	Government: Force was excessive and unreasonable under factors (age, instrument, injuries, manner)	Held: Sufficient evidence government rebutted privilege; force was excessive and unreasonable
Whether the wooden stick was a "dangerous weapon" for attempted PPW	Johnson: Stick did not produce great bodily injury and so was not a dangerous weapon	Government: Ordinary objects may be dangerous in use; here repeated force, breakage, and injuries made it dangerous	Held: Sufficient evidence the stick, as used, was a dangerous weapon and supported attempted PPW conviction

Morales v. United States, 866 A.2d 67 (D.C. 2005) (custody assessed by totality and whether restraint equals formal arrest)
California v. Beheler, 463 U.S. 1121 (1983) (Miranda custody requires formal arrest or equivalent restraint)
Berkemer v. McCarty, 468 U.S. 420 (1984) (custody judged by how a reasonable person would perceive freedom of movement)
Jones v. United States, 779 A.2d 277 (D.C. 2001) (appellate review: defer to trial court fact findings on suppression; legal question reviewed de novo)
Lee v. United States, 831 A.2d 378 (D.C. 2003) (parental-discipline privilege and burden on government to disprove disciplinary purpose or reasonableness)
Florence v. United States, 906 A.2d 889 (D.C. 2006) (example of lawful, measured corporal discipline contrasted here)
Alfaro v. United States, 859 A.2d 149 (D.C. 2004) (ordinary objects can be dangerous weapons depending on manner of use)
Stroman v. United States, 878 A.2d 1241 (D.C. 2005) (actual injury is important but not dispositive in determining dangerousness)
Harper v. United States, 811 A.2d 808 (D.C. 2002) (definition of dangerous weapon focuses on likelihood of producing death or great bodily injury)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda rights required when custodial interrogation exists)