113 N.E.3d 290
Ind. Ct. App.2018Background
- On July 29, 2016, Officer James Paris responded to a 2:09 a.m. call from Ashley Reid’s husband reporting a loud noise, seeing Reid "staggering" in the driveway, and a belief she had struck something with her vehicle.
- On arrival Paris observed two women, a vehicle with fresh-looking damage (rear passenger bumper and shredded front passenger tire), and Reid, who admitted she had driven the vehicle and showed signs of intoxication (unsteady, bloodshot eyes, odor of alcohol).
- Paris questioned Reid in the driveway (asked her to step back, put out a cigarette, and describe the damage); Reid gave inconsistent answers about when/where damage occurred and admitted driving earlier that evening.
- Paris conducted standardized field sobriety tests, Reid failed multiple tests, registered .169 on a portable breath test, refused a chemical test, was handcuffed and transported to hospital, and Paris obtained a warrant for blood testing.
- Reid moved to suppress all statements and test results, arguing she was in custody and subject to custodial interrogation without Miranda warnings and that Fourth and Article 1, §11 protections were violated. The trial court denied the motion; the interlocutory appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Reid was seized/subject to an unconstitutional Fourth Amendment detention when Officer Paris questioned her in the driveway | Reid: questioning and directives (where to stand, put out cigarette), isolation, accusatory tone, and detention made a reasonable person feel not free to leave, so detention required reasonable suspicion or probable cause | State: encounter began consensual and evolved to a Terry investigatory stop supported by reasonable suspicion (call from husband, observed intoxication, fresh vehicle damage, admissions) | Court: No Fourth Amendment violation; officer had reasonable suspicion under totality of circumstances and conduct was a permissible investigatory stop |
| Whether Reid was subjected to custodial interrogation requiring Miranda warnings (Fifth Amendment) | Reid: questioning at her home, accusatory and coercive, and statements were used to order sobriety tests and obtain a warrant—she was effectively in custody and should have received Miranda warnings | State: Reid was not in custody during questioning in the driveway; Miranda not triggered; later physical evidence (breath tests) is noncommunicative and admissible | Court: No Miranda violation; under totality of circumstances Reid was not in custody when she made statements |
| Whether officer conduct violated Article 1, §11 of Indiana Constitution (state search/seizure reasonableness) | Reid: intrusion on home curtilage and accusatory questioning made the stop unreasonable; police needs were insufficient to justify intrusion | State: police had strong law-enforcement interest (drunk driving), limited intrusion, and substantial articulable facts to justify investigation | Court: No violation of Article 1, §11; balancing factors show reasonableness under totality of circumstances |
Key Cases Cited
- Robinson v. State, 5 N.E.3d 362 (Ind. 2014) (standard of review for suppression rulings and separate state-constitution analysis)
- Terry v. Ohio, 392 U.S. 1 (1968) (police may make brief investigatory stops on reasonable suspicion)
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings before statements may be used)
- Arvizu v. United States, 534 U.S. 266 (2002) (reasonable-suspicion determination by totality of circumstances)
- Hardister v. State, 849 N.E.2d 563 (Ind. 2006) (knock-and-talk/curtilage approach and limits on intrusions)
- Luna v. State, 788 N.E.2d 832 (Ind. 2003) (questioning a suspect alone does not automatically create custody for Miranda)
- Brown v. State, 70 N.E.3d 331 (Ind. 2017) (custody inquiry requires totality of circumstances to determine restraint comparable to formal arrest)
- Beheler v. United States, 463 U.S. 1121 (1983) (custody analysis focuses on formal arrest or comparable restraint)