State v. BIELSKIES, 249 P.3d 144

Officer observed Bielskies driving with a suspended license and stopped him at his home.
During the stop, Bielskies was handcuffed; officer found a pill bottle with various pills, cash, and a paper drug ledger.
Officer later questioned Bielskies about drug dealing while transporting him, without Miranda warnings, noting that nothing said would be admissible.
After taking Bielskies to a precinct, the officer gave Miranda warnings; Bielskies waived and admitted selling pills to support an addiction.
Pre-Miranda statements were suppressed; post-Miranda statements were admitted at trial after appellate questions.
Court applied Oregon Supreme Court guidance from Vondehn that belated warnings can render post-warning statements admissible when effectively given.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pre-Miranda questioning violated Article I, section 12 requiring suppression.	Bielskies argues pre-Miranda questioning taints later statements.	State contends post-Miranda statements are independent of unwarned questioning.	Pre-Miranda statements suppressed.
Whether belated Miranda warnings rendered the post-Miranda statements admissible under Article I, section 12.	Prosecution argues post-Miranda statements remain admissible if belated warnings are effective.	Bielskies contends belated warnings do not cure the violation.	Post-Miranda statements admitted; belated warnings effective under Vondehn standard.
What is the proper test for evaluating the effectiveness of belated warnings under Oregon law?	Court should adopt a mixed-message approach to assess waiver validity.	Waiver should be deemed involuntary if warnings are not effectively delivered.	Court adopts objective, multi-factor analysis from Vondehn to assess belated warnings.

State v. Vondehn, 348 Or. 462 (Or. 2010) (belated Miranda warnings may render post‑warning statements admissible)
State v. Hall, 339 Or. 7 (Or. 2005) (exploration of exploitation doctrine applicable to Article I, section 9)