In re T.W.
2012 Ohio 2361
Ohio Ct. App.2012Background
- State charged T.W. with gross sexual imposition based on alleged inappropriate contact with his four-year-old half-sister.
- Interview of T.W. at Marion County Children Services occurred when he was fourteen; he was not formally arrested.
- T.W. and his parents were told they could accompany him, but not allowed to stay in the interview room; officer wore a uniform and firearm.
- The interview lasted about one hour; T.W. denied the conduct multiple times before making a written admission.
- The trial court granted a suppression motion, determining the interview was custodial; the state appealed.
- The appellate court affirmed, holding Miranda warnings were required because T.W. was in custody during the interview.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether T.W. was in custody for Miranda purposes. | State contends no custody required Miranda warnings. | T.W. was in custody given age, setting, and officers’ control; warning required. | Yes, custody found; Miranda warnings required. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires warnings and rights advisement)
- State v. Biros, 78 Ohio St.3d 426 (Ohio 1997) (custodial analysis; not all questioning triggers Miranda)
- State v. Gumm, 73 Ohio St.3d 413 (Ohio 1995) (totality of circumstances governs custody inquiry)
- Beheler v. California, 463 U.S. 1121 (U.S. 1983) (non-coercive setting; but relevant to custody analysis in totality)