Cleveland v. Oles (Slip Opinion), 152 Ohio St. 3d 1

Trooper stopped Benjamin Oles after observing unsafe driving; trooper smelled alcohol and asked Oles to exit his car.
Trooper directed Oles to sit in the front seat of the patrol car; trooper did not pat down Oles, take his keys, or tell him the vehicle would be searched.
While seated in the patrol car, the trooper asked where Oles was coming from and how much he had drunk; Oles said four mixed drinks.
Trooper then conducted brief field-sobriety tests, arrested Oles after failures, and placed him in the back of the patrol car. No Miranda warnings were given.
Cleveland Municipal Court suppressed Oles’s statements; the Eighth District affirmed and certified a conflict with other appellate districts.
Ohio Supreme Court held that front-seat placement alone does not mandate Miranda; reversed suppression and remanded, applying a totality-of-circumstances custodial test.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether placing a motorist in the front seat of a police vehicle during a traffic stop automatically triggers Miranda.	Oles: being removed from his car and placed in the cruiser made him "in custody," so Miranda warnings were required.	Cleveland: front-seat questioning during a routine traffic stop is not automatically custodial; need totality-of-circumstances analysis.	Front-seat placement alone is not determinative; apply totality-of-the-circumstances to ask whether a reasonable person would have felt in custody.

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings protect against custodial coercion)
Berkemer v. McCarty, 468 U.S. 420 (traffic stops are ordinarily noncustodial; custody depends on how a reasonable person would perceive the situation)
State v. Farris, 109 Ohio St.3d 519 (Ohio: front-seat questioning can be custodial when officer’s conduct conveys detention long enough to search)
United States v. Patane, 542 U.S. 630 (distinguishing Miranda warnings from the exclusion of physical evidence in some contexts)