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People of Michigan v. John Edward Barritt
333206
| Mich. Ct. App. | Feb 14, 2017
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Background

  • 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)
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Case Details

Case Name: People of Michigan v. John Edward Barritt
Court Name: Michigan Court of Appeals
Date Published: Feb 14, 2017
Docket Number: 333206
Court Abbreviation: Mich. Ct. App.