People v. Steele
292 Mich. App. 308
| Mich. Ct. App. | 2011Background
- Loss-prevention informed police that a suspect purchased Sudafed (precursor) in packages and Coleman fuel, and left Meijer in a Ford Taurus.
- Officer Doxtader located the Taurus on US-127, conducted an investigative stop, and briefly questioned the driver.
- Defendant denied having a license; he was ordered out and asked about contraband; he admitted meth in the vehicle door and loaded materials for manufacture.
- Defendant was arrested for meth possession and driving without a license; officer later searched the vehicle and recovered meth.
- Defendant was transported to the station; Miranda warnings were given and waived; he gave a second interview reiterating prior statements.
- Defendant moved to suppress both the roadside and station statements and the vehicle evidence as fruits of an illegal stop and custodial interrogation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop based on reasonable suspicion? | State: combined training and reliable tip created reasonable suspicion. | Defendant: purchase of precursors alone insufficient for suspicion. | Stop justified; reasonable suspicion supported by precursors and training. |
| Were the roadside statements Miranda-protected custody or not? | State: stop was Terry-like; statements permissible without Miranda. | Defendant: custodial interrogation requiring Miranda warnings at roadside. | Statements admissible; not a custodial interrogation under Miranda. |
| Are station-house statements tainted by an illegal roadside stop? | State: taint notwithstanding; later interrogation separate after warnings. | Defendant: taint from unlawful stop invalidates later statements. | Second statements at police department lawful; taint not applied to require suppression. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (required warnings for custodial interrogation)
- Berkemier v. McCarty, 468 U.S. 420 (U.S. 1984) (traffic stops are not custodial under Miranda)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (reasonable suspicion for brief investigative stop)
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality-of-the-circumstances standard for reasonable suspicion)
- Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (post-Ma caveats on curative warnings and custodial interrogation)
- Coomer v. Yukins, 533 F.3d 477 (6th Cir. 2008) (Miranda warnings can purge taint from prior statements when distinct interrogation occurs)
- Maryland v. Shatzer, 559 U.S. 98 (U.S. 2010) (custodial custody analysis during traffic stops and detentions)
- Oliver v. United States, 464 Mich. 184 (Mich. 2001) (reasonableness of inferences from police training and vehicle stops)
- People v. Hill, 429 Mich. 382 (Mich. 1987) (Miranda warnings not required absent custodial interrogation)