State of Minnesota v. Erik John Heinonen, 889 N.W.2d 817

Officers executed a search warrant at a residence, handcuffed three occupants (including Heinonen) and secured the scene; officers told occupants they were not under arrest.
During brief on-scene questioning Heinonen gave his name, DOB, and said he had been in the upstairs southwest bedroom.
While searching that bedroom officers found shotgun shells and a short-barreled shotgun; Heinonen was later arrested when officers learned he was a prohibited person.
At the jail officers asked Heinonen (without rereading Miranda) to consent to a DNA swab; he signed a consent form and volunteered he had touched the firearm.
Heinonen moved to suppress his on-scene statements, the volunteered admission, and the DNA sample; the district court denied suppression and a jury convicted him of possessing a short-barreled shotgun and being a prohibited person in possession of a firearm.

Issue	Plaintiff's Argument (Heinonen)	Defendant's Argument (State)	Held
1. Were on-scene statements made in custody and thus subject to Miranda suppression?	On-scene questioning while handcuffed before Miranda rendered him "in custody"; responses should be suppressed.	Handcuffing and brief questions while securing the house were routine, not custodial interrogation.	Court: Not custodial interrogation; statements admissible.
2. Did officers violate Miranda by requesting consent for a DNA swab after Heinonen invoked right to remain silent?	Requesting DNA consent after invocation was the functional equivalent of interrogation likely to elicit incriminating response; fruits should be suppressed.	A DNA-consent request is not interrogation; DNA is physical (non-testimonial) evidence and consent requests are normally attendant to custody.	Court: Request did not constitute interrogation; DNA is non-testimonial; evidence admissible.

Miranda v. Arizona, 384 U.S. 436 (landmark Fifth Amendment custodial-interrogation rule)
Rhode Island v. Innis, 446 U.S. 291 (definition of "interrogation" includes words/actions police should know are reasonably likely to elicit incriminating response)
Schmerber v. California, 384 U.S. 757 (Fifth Amendment does not protect physical evidence taken from the body)
Holt v. United States, 218 U.S. 245 (distinguishing compelled testimony from use of the body as evidence)
State v. Walsh, 495 N.W.2d 602 (on-the-scene questioning does not always require Miranda)
State v. Rosse, 478 N.W.2d 482 (custody factors where extended questioning in squad car and show of force found custodial)
State v. Vue, 797 N.W.2d 5 (factors indicating custody versus noncustodial context)
State v. Greenleaf, 591 N.W.2d 488 (question about waiving extradition not interrogation under Miranda)