People v. Wright
2011 IL App (4th) 100047
Ill. App. Ct.2011Background
- Defendant Bruce E. Wright was charged with driving while license revoked (DWR) and aggravated DUI with BAC ≥0.08 after a June 2009 traffic stop and subsequent testing.
- Deputy Renken stopped Wright knowing Wright’s license was revoked; Renken’s stop led to Wright’s transport to a location where sobriety testing occurred.
- Wright admitted drinking at Morgan’s residence and later consented to blood and urine tests; toxicology showed BAC 0.134 and Valium in urine.
- Trial court denied Wright’s motion to suppress statements and toxicology results; Wright was convicted after a bench trial in August 2009.
- Wright was sentenced to two four-year extended terms, to be served concurrently, in October 2009.
- On appeal Wright contends the motion to suppress should have been granted because Miranda warnings were not given when Wright was placed in the squad car.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wright was in custody for Miranda purposes during transport. | Wright argues he was in custody once placed in the squad car. | Wright contends the custodial setting triggered Miranda warnings. | Not custody; statements admissible. |
| Whether blood and urine toxicology results should be suppressed for lack of Miranda warnings. | Miranda warnings were not required to obtain the tests. | Tests obtained after arrest without warnings should be suppressed as custodial interrogation. | No suppression; testing admissible as non-Miranda physical evidence. |
| What standard governs suppression rulings on appeal. | Standard should review factual findings for weight and legal decisions de novo. | Two-part standard applied; factual findings require deference, ultimate ruling de novo. |
Key Cases Cited
- People v. Seiler, 406 Ill. App. 3d 352 (2010) (two-part standard of review for suppression rulings: factual findings need be weight-of-evidence, ultimate ruling de novo)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (custody for Miranda purposes during traffic stops requires custodial restraints akin to arrest)
- Ashcroft v. Al-Kidd, 131 S. Ct. 2074 (2011) (objective arrest justification; unrevealed motives not controlling)
- People v. Slater, 228 Ill. 2d 137 (2008) (factors for determining custodial interrogation status)
- People v. Gorman, 207 Ill. App. 3d 461 (1991) (threshold analysis of whether suspect believed custody for Miranda)