Ryan E. Bean v. State of Indiana
973 N.E.2d 35
Ind. Ct. App.2012Background
- Bean was interrogated at a police station after being escorted there by an officer, not under arrest at the outset.
- Police initially pursued a child-pornography investigation and disclosed the real focus—allegations by H.B. and M.S.—after Bean arrived at the station.
- Bean invoked his Miranda rights and signed a waiver after reminders of those rights; he contended he asked for a lawyer during questioning.
- The interrogation spanned about two to two-and-a-half hours, with Bean denying molestation for H.B. and M.S. before confessing to H.B. around 7:00 p.m.
- Bean was eventually arrested after his confession; White County and Carroll County pursued separate molestation charges, with severance of M.S. in White County.
- The trial courts admitted Bean’s September 23, 2010 confession; Bean challenged its admissibility, leading to consolidated appeals in Carroll and White Counties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bean's confession was admissible after invoking counsel | State contends custodian invoked rights yet continued questioning; not clearly in custody enough to suppress. | Bean unequivocally invoked the right to counsel; interrogation should have ceased. | Confession suppressed; invocation honored; custodial interrogation found. |
| Whether Bean was in custody for Miranda purposes at confession | Custody not established; Miranda warnings read well before confession; environment not inherently coercive. | Totality of circumstances shows custody existed when confession occurred. | Bean was in custody at confession; custodial analysis supported suppression. |
| Whether the erroneous admission of the confession was harmless | Harmless error since other evidence supported convictions. | Confession was central; without it convictions unreliable. | Not harmless beyond a reasonable doubt; reversal required. |
Key Cases Cited
- Luna v. State, 788 N.E.2d 832 (Ind. 2003) (voluntary interview not custody; Miranda not triggered)
- Morris v. State, 871 N.E.2d 1011 (Ind. Ct. App. 2007) (custody determined after multiple interviews; later confession)
- Sprosty v. Buchler, 79 F.3d 635 (7th Cir. 1996) (factors for custody; warnings vs. custody timing)
- Carr v. State, 934 N.E.2d 1096 (Ind. 2010) (interrogation after invoking rights; necessity of cessation)
- Anderson v. State, 961 N.E.2d 19 (Ind. Ct. App. 2012) (unambiguous invocation of counsel required; clarity standard)
- Ackerman v. State, 774 N.E.2d 970 (Ind. Ct. App. 2002) (custody analysis when transported for questioning; Miranda considerations)
- Collins v. State, 873 N.E.2d 149 (Ind. Ct. App. 2007) (context of custody and Miranda within coercive environments)
- Bautista, 145 F.3d 1140 (10th Cir. 1998) (miranda warnings and ongoing interrogation; rights invocation)