People v. White, 493 Mich. 187

Defendant was 17 at the time and charged with felony murder, armed robbery, and possession of a firearm during the commission of a felony.
After custody and Miranda advisement, defendant invoked the right to remain silent.
Detective Stiles stated, “I’m not asking you questions, I’m just telling you,” and then said, “I hope that the gun is in a place where nobody can get a hold of it and nobody else can get hurt by it.”
The officer’s comment was scrutinized to determine whether it was the functional equivalent of interrogation under Innis.
The Court of Appeals held no interrogation occurred; the trial court had suppressed the confession; the Supreme Court granted review.
The majority affirmatively concluded defendant was not subjected to interrogation after invoking silence; the confession is admissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the post-invocation statement constitutes interrogation	White argues the comment was the functional equivalent of questioning	White contends the remark was an interrogation tactic after invocation	No interrogation; confession admissible following invocation
Whether the remark is express questioning or its functional equivalent	White asserts the remark invited a response and thus was interrogation	White contends the remark was a non-question expressing concern for safety	Not express questioning; no functional equivalent under Innis
Standard of review for interrogation issue	Court should review de novo as law based on undisputed facts	Standard should focus on police intent and suspect perception	De novo review; standard applied but harmless error due to ultimate holding in favor of non-interrogation

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (established Miranda warnings; interrogation must cease if silence invoked)
Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (defines interrogation as express questioning or its functional equivalent)