State of Maine v. Luke A. Bryant, 97 A.3d 595

On Feb. 19, 2011 police responded to a shooting at Luke Bryant’s apartment; the victim died and police believed it may have been accidental.
Detective Bosco obtained Bryant’s consent to a 15-minute, audio-recorded interview in Bryant’s bedroom; Bosco was in plain clothes, non‑confrontational, and did not arrest or restrain Bryant.
Later Detective Andrews (plain clothes) conducted a roughly two‑hour, audio‑recorded interview in an unmarked cruiser (Bosco present for much of it); Andrews repeatedly told Bryant he was not under arrest and was free to leave; no Miranda warnings were given.
The detectives later conducted a 25‑minute, video‑recorded walk‑through reenactment in the apartment with Bryant’s consent. Bryant left afterward; he was later indicted for manslaughter and moved to suppress his statements.
The suppression court denied the motion, finding the interviews non‑custodial and the statements voluntary; a jury convicted Bryant of manslaughter and the conviction was appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bryant was "in custody" for Miranda purposes during the interviews	State: interviews were non‑custodial because Bryant consented, was in familiar surroundings, and was told he was free to leave	Bryant: presence of officers and circumstances made a reasonable person feel they could not leave (custodial interrogation)	Court: Not custodial — objective factors (locale, consent, plain clothes, no restraints, repeated statements that he was free to leave, investigatory focus) weigh against custody
Whether Bryant’s statements were voluntary	State: statements were the product of free choice — non‑confrontational, no coercion or promises, familiar setting	Bryant: shock and emotional distress rendered statements involuntary	Court: Statements voluntary beyond a reasonable doubt — totality of circumstances shows rational, uncoerced cooperation

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation)
Rhode Island v. Innis, 446 U.S. 291 (definition of "interrogation" for Miranda)
State v. Michaud, 724 A.2d 1222 (Me. 1998) (factors for custody analysis)
State v. Nightingale, 58 A.3d 1057 (Me. 2012) (voluntary, non‑custodial interview where defendant consented)
State v. Sawyer, 772 A.2d 1173 (Me. 2001) (totality‑of‑circumstances test for voluntariness)
State v. Lowe, 81 A.3d 360 (Me. 2013) (statements voluntary despite emotional distress)
State v. Coombs, 704 A.2d 387 (Me. 1998) (de novo review of voluntariness when facts undisputed)