Jose Castillo-Aguilar v. State of Indiana, 2012 Ind. App. LEXIS 21

Castillo-Aguilar, who spoke little English, was stopped for a cracked windshield and arrested for driving without a license.
At the Goshen Police Department, he was given a Spanish/English Information Sheet to fill out identifying information, including employer name.
No Miranda warning was given prior to completing the Information Sheet.
The employer identified Castillo-Aguilar as another named employee; a later I-9 form showed a false name.
The State charged Class C felony forgery based on false documentation; Castillo-Aguilar moved to suppress the Information Sheet responses and related evidence, which the trial court denied.
The court here reverses, holding Miranda warnings were required before the Information Sheet and the information should be suppressed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Castillo-Aguilar subjected to custodial interrogation when completing the Information Sheet?	Castillo-Aguilar	Castillo-Aguilar	Yes; interrogation occurred requiring Miranda warnings.
Were the Information Sheet questions administrative or investigative in purpose?	State	Castillo-Aguilar	Totality of circumstances shows interrogation for investigation.
Did the lack of Miranda warnings require suppression of the Information Sheet responses and subsequent evidence?	State	Castillo-Aguilar	Yes; statements and evidence must be suppressed.

Loving v. State, 647 N.E.2d 1123 (Ind. 1995) (identification questions during custody may be noncustodial; but context matters for Miranda)
Keller, 845 N.E.2d 154 (Ind. 2006) (totality of circumstances governs Miranda applicability)
Curry v. State, 643 N.E.2d 963 (Ind. Ct. App. 1994) (limited, focused inquiries during arrest may not constitute custodial interrogation)
Deckard v. State, 670 N.E.2d 1 (Ind. Ct. App. 1996) (Miranda warnings not required when asking only name/age)
King v. State, 844 N.E.2d 92 (Ind. Ct. App. 2005) (custodial interrogation without Miranda warnings requires suppression)