State v. Brown, 2016 Ohio 4973

Dayton officer stopped Brown for a traffic violation (no license-plate illumination); passenger fled, was chased, caught, handcuffed and placed in patrol car.
Officer Schwartz escorted Brown from his vehicle into the back seat of the cruiser because Brown had no driver’s license; Brown was not handcuffed and was not told he was under arrest.
The cruiser’s rear doors do not open from the inside and were locked while officers processed the scene and prepared to tow the vehicle.
During an inventory search of the car, another officer found a baggie of suspected crack cocaine near the driver’s door; Officer Schwartz displayed the bag and asked, “Whose drugs are these?”
Brown answered “It’s mine” before receiving Miranda warnings; the officer then read Miranda and placed Brown under arrest. Brown was indicted for possession and moved to suppress the statement.
The trial court suppressed Brown’s pre‑Miranda admission; the State appealed the suppression order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown was in custody when asked about the drugs, requiring Miranda warnings	The stop was investigative and routine; Brown was not under arrest, not handcuffed, and would reasonably expect to be cited and released	A reasonable person would feel not free to leave: locked rear doors, detained in cruiser after passenger’s arrest, and drugs were displayed before questioning	The court held Brown was in custody for Miranda purposes; the pre‑Miranda statement is suppressed

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation)
Berkemer v. McCarty, 468 U.S. 420 (1984) (routine traffic stops are ordinarily noncustodial; limited questioning allowed)
Thompson v. Keohane, 516 U.S. 99 (1995) (custody determination is objective: would a reasonable person feel free to terminate the encounter)
Moran v. Burbine, 475 U.S. 412 (1986) (Miranda grounded in Fifth Amendment protection against compelled self‑incrimination)
Oregon v. Mathiason, 429 U.S. 492 (1977) (custody depends on restraint on freedom of movement and circumstances of interrogation)