State of Tennessee v. Kyle J. Dodd, W2017-00733-CCA-R3-CD

Trooper Mealer responded to a pickup-truck accident and went to the nearby house where Kyle J. Dodd had been staying to question him.
Dodd admitted driving the truck, initially denied drinking, performed field sobriety tests, then admitted he had a drink earlier that night.
Dodd consented to a blood draw and was arrested for DUI, second offense.
Before trial Dodd moved to suppress his statements, the field sobriety video, and blood results arguing Miranda violations.
The trial court denied suppression, finding no Miranda requirement for the initial questioning and that the admission was voluntary.
On appeal Dodd challenged suppression, but did not raise the issue in a timely motion for new trial, so the Court of Criminal Appeals reviewed only for plain error and declined to find plain error.

Issue	State's Argument	Dodd's Argument	Held
Whether Trooper Mealer’s failure to give Miranda warnings required suppression of Dodd’s statements and derivative evidence	Mealer’s on-scene questioning did not trigger Miranda; statements voluntary and admissible	Failure to advise Miranda required suppression of statements and evidence derived from them	Appeal waived for failure to raise in new-trial motion; plain-error review denied and trial court affirmed

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes requirement to advise suspects of rights before custodial interrogation)
State v. Maynard, 629 S.W.2d 911 (Tenn. Crim. App. 1981) (failure to raise suppression issue in a new-trial motion waives appellate review)
State v. Page, 184 S.W.3d 223 (Tenn. 2006) (sets five-factor plain-error test)
State v. Terry, 118 S.W.3d 355 (Tenn. 2003) (discusses plain-error standard)
State v. Henning, 975 S.W.2d 290 (Tenn. 1998) (appellate courts may consider suppression hearing and trial proof when reviewing suppression rulings)
State v. Climer, 400 S.W.3d 537 (Tenn. 2013) (erroneous admission of Miranda-tainted evidence subject to harmless-error analysis)