State of Indiana v. Brandon Battering, 85 N.E.3d 605

In late 2015 Brandon Battering was accused of sexual misconduct involving his then-12‑year‑old stepsister and an explicit Facebook message. These remained allegations at the interlocutory stage.
On December 3, 2015 Battering voluntarily attended an interview with Pulaski County Deputy Nicolas Bowyer and Lafayette Det.-Sgt. Robert Goldsmith and initially denied the allegations.
Mid‑interview Battering said, “Honestly, I’m done with answering questions right now,” and expressed frustration. Goldsmith responded and continued the interview without rereading Miranda warnings.
After Goldsmith’s continued engagement and persuasion, Battering resumed talking and made incriminating admissions by the end of the interview.
Battering moved to suppress the pre‑trial statements; the trial court granted the motion. The State obtained interlocutory appellate review, and this Court affirmed the suppression order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Battering unequivocally invoked his Miranda right to remain silent when he said he was “done with answering questions right now.”	The State: the statement was equivocal or mere reluctance; officers permissibly continued and elicited statements.	Battering: the statement was an unambiguous invocation of the Fifth Amendment right to remain silent and interrogation had to cease.	Court: Battering’s statement was an unequivocal invocation; officers should have stopped and not continued without re‑advising rights; suppression proper.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes right to remain silent and prohibition on custodial interrogation without warnings)
Washington v. State, 808 N.E.2d 617 (Ind. 2004) (interrogation must cease when suspect indicates wish to remain silent)
Clark v. State, 808 N.E.2d 1183 (Ind. 2004) (assertion of Miranda rights must be clear and unequivocal; statements considered as a whole)
Powell v. State, 898 N.E.2d 328 (Ind. Ct. App. 2008) (mere reluctance to talk is insufficient to invoke right; analysis is fact‑sensitive)
Haviland v. State, 677 N.E.2d 509 (Ind. 1997) (reviews fact‑sensitive nature of invocation determinations)