139 N.E.3d 237
Ind. Ct. App.2019Background
- Michael Scanland, a 1995 murder convict, was on parole under an agreement permitting reasonable searches of his person/residence when officers had reasonable cause to believe a parole violation occurred.
- After a neighborhood dispute, parole agent Eric Vanatti encountered Scanland at an IMPD station; Vanatti believed Scanland was under the influence and asked for a urine screen.
- Scanland refused the drug test, admitted he had used methamphetamine, was handcuffed, and — while Vanatti was completing a transmittal form — voluntarily told Vanatti he had smoked meth and asked Vanatti to retrieve a pipe hidden in a sock in his dresser.
- Officers went to Scanland’s home, found two pipes with meth residue in his bedroom, obtained a search warrant, and later charged Scanland with possession of methamphetamine (felony) and possession of paraphernalia (misdemeanor).
- Scanland moved to suppress his statements and the pipes as products of custodial interrogation without Miranda warnings; the trial court denied suppression, a jury convicted him of possession of paraphernalia, and he appealed.
Issues
| Issue | State's Argument | Scanland's Argument | Held |
|---|---|---|---|
| 1) Were Scanland’s in‑custody statements the product of custodial interrogation requiring Miranda warnings? | The statements were volunteered; although Scanland was handcuffed, Vanatti did not ask questions that were the functional equivalent of interrogation. | Handcuffing and Vanatti’s conduct created the functional equivalent of interrogation; Miranda warnings were required. | Scanland was in custody but not subject to interrogation; his statements were volunteered and admissible. |
| 2) Was the subsequent search of Scanland’s home unreasonable because it flowed from allegedly inadmissible statements? | The parole agreement authorized reasonable searches on reasonable cause; Scanland’s behavior, refusal to submit to testing, and admissions provided reasonable cause to search. | If the statements were inadmissible, they could not provide reasonable cause and the search was unlawful. | Statements were admissible; under the parole agreement the facts provided reasonable cause to search, so the pipes were properly admitted. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings requirement)
- Rhode Island v. Innis, 446 U.S. 291 (1980) (defines "functional equivalent" of interrogation)
- Brewer v. Williams, 430 U.S. 387 (1977) (example of police words constituting interrogation)
- Hartman v. State, 988 N.E.2d 785 (Ind. 2013) (discusses Fifth Amendment protections/state application)
- State v. Brown, 70 N.E.3d 331 (Ind. 2017) (custody test for Miranda purposes)
- State v. Ruiz, 123 N.E.3d 675 (Ind. 2019) (custody is a mixed question of law and fact)
- Bailey v. State, 763 N.E.2d 998 (Ind. 2002) (statements from custodial interrogation are generally inadmissible without Miranda)