People of Michigan v. John Edward Barritt
333206
| Mich. Ct. App. | Feb 14, 2017Background
- Defendant voluntarily went to the police station and agreed to ride in a marked police car to answer questions.
- The interview occurred in a station room with the door closed but not locked; officers came and went freely.
- Defendant was not restrained, was offered a beverage, and engaged in casual conversation with officers.
- Defendant repeatedly indicated a desire to help the investigation and was told twice he could end the interview at any time and was not under arrest.
- The sole contested legal question was whether the interview was a custodial interrogation requiring Miranda warnings; the authoring judge would reverse suppression and hold warnings were not required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stationhouse interview was a "custodial interrogation" triggering Miranda warnings | The State argued the circumstances reflected custody requiring Miranda warnings for admissibility | Barritt argued he was not free to leave and thus was in custody, so warnings were required | The opinion held the interview was not custodial; Miranda warnings were not required and suppression should have been denied |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation triggers right to warnings)
- Stansbury v. California, 511 U.S. 318 (1994) (custody is determined by objective circumstances)
- Oregon v. Mathiason, 429 U.S. 492 (1977) (voluntary stationhouse interview not necessarily custodial)
- Illinois v. Perkins, 496 U.S. 292 (1990) (concern limited to pressures that deprive freedom to leave)
- People v. Mendez, 225 Mich. App. 381 (1997) (whether person reasonably believes free to leave is key)
- People v. Steele, 292 Mich. App. 308 (2011) (application of totality-of-circumstances custody test)
