People of Michigan v. Patrick Dean Stiles, 332459

Defendant Patrick Stiles, an inmate at Montcalm County Jail, was ordered to be strip-searched after a tip that he possessed a contraband cell phone.
Officers escorted Stiles (not handcuffed) into a locked inmate property room to conduct the search; before the search an officer asked if he had anything he was not supposed to have.
Stiles answered affirmatively and removed a cell phone from his underwear; officers and chain-of-custody witnesses later testified about the phone’s recovery at trial.
Defense sought suppression of Stiles’s statement as a custodial interrogation in violation of Miranda; the circuit court found the setting custodial but allowed the officer’s initial safety question, suppressing subsequent questioning.
At trial, officer testimony improperly revealed Stiles’s statement that it was a cell phone; the court denied a mistrial, gave curative instructions (some with defense approval), and the jury convicted after brief deliberation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer’s pre-search question required Miranda warnings	The question was a permissible noncoercive safety/booking inquiry outside Miranda	The setting was custodial and the question elicited incriminating testimonial evidence without Miranda warnings	Court assumed without deciding Miranda applicability because outcome unaffected; admissibility unnecessary to resolve
Whether the cell phone would have been suppressed absent the statement (inevitable discovery)	The phone was inevitably discoverable via the lawful strip search; statement irrelevant	Statement produced discovery; without it phone might not have been revealed	Court held inevitable discovery applied: the search would have yielded the phone and its discovery was inevitable
Whether admission of the statement and denial of mistrial were reversible error (harmlessness)	Any error was harmless because untainted physical evidence (the phone, custody testimony) overwhelmingly proved guilt	Admission of statement (and prosecutor’s question) prejudiced jury; mistrial warranted	Court found any Miranda error harmless beyond a reasonable doubt and denial of mistrial not an abuse of discretion; conviction affirmed

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation)
Nix v. Williams, 467 U.S. 431 (inevitable discovery exception to exclusionary rule)
Arizona v. Fulminante, 499 U.S. 279 (constitutional-error harmlessness framework)
Neder v. United States, 527 U.S. 1 (harmless-error standard)
People v. Steele, 292 Mich. App. 308 (appellate review of suppression rulings)
People v. Jenkins, 472 Mich. 26 (Fourth Amendment application review)
People v. Mass, 464 Mich. 615 (harmless-error discussion in Michigan law)
People v. Anderson (After Remand), 446 Mich. 392 (standard for no reasonable possibility of contributing to conviction)
People v. Schaw, 288 Mich. App. 231 (mistrial standard)