State v. Bridges
125 Conn. App. 72
| Conn. App. Ct. | 2010Background
- Defendant Bridges moved to suppress statements and evidence from a September 4, 2007 custodial interrogation about a August 29, 2007 burglary/larceny; the court conducted an evidentiary hearing in July 2008 and denied suppression.
- Police sought to question Bridges after identifying him from surveillance photos; he voluntarily accompanied detectives to a police interview room, with door open, and was informed he was not under arrest and could leave.
- The defense argued lack of Miranda warnings and that statements were involuntary as the fruits of an unlawful interrogation.
- The trial court found Bridges was not in custody and thus not entitled to Miranda warnings; it concluded the interrogation was noncustodial and the statements were admissible.
- On appeal, the Connecticut Appellate Court reviewed custody as a mixed question of law and fact and affirmed the suppression ruling, holding no custodial interrogation occurred.
- The judgment included Bridges also facing a persistent felony offender sentence after a guilty plea matter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bridges was in custody for Miranda purposes | State maintains no custody; defendant voluntarily spoke and was free to leave | Bridges was in police custody and Miranda warnings were required | Not custody; warnings not required. |
Key Cases Cited
- State v. Mullins, 288 Conn. 345 (2008) (two-step custody analysis; de novo review on legal questions)
- State v. Britton, 283 Conn. 598 (2007) (voluntary accompaniment supports noncustody finding)
- State v. Turner, 267 Conn. 414 (2004) (not custodial where not under arrest and free to leave)
- State v. Atkinson, 235 Conn. 748 (1996) (factors indicating custody; freedom to leave; unarmed, unlocked setting)
- State v. Pinder, 250 Conn. 385 (1999) (warning indicators; leaving interview as evidence of noncustody)
- State v. Northrop, 213 Conn. 405 (1990) (custody determination; objective assessment of surroundings)
- State v. Greenfield, 228 Conn. 62 (1993) (consent/leave-freedom as custody factor)
- Stansbury v. California, 511 U.S. 318 (1994) (custody assessment; subjective views of officer not controlling)