State v. C.D., 947 N.E.2d 1018

On January 8, 2010, Mooresville High School personnel received a report that a student appeared under the influence.
C.D. was brought to the assistant principal’s office for evaluation of possible impairment.
The assistant principal summoned Richhart, a security officer who is also a Mooresville Police Department officer in uniform.
Richhart, a drug recognition evaluator, conducted a ten-minute examination of C.D.
After the examination, Richhart concluded C.D. was under the influence of marijuana and C.D. admitted prior smoking.
Vanwanzeele searched C.D.’s backpack and found two Adderall pills; the State filed a delinquency petition; the trial court suppressed evidence obtained before parental consultation; the State dismissed and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Custodial interrogation and Miranda/IC safeguards	State argues custodial interrogation occurred; Miranda/IC safeguards apply	C.D. argues no custodial interrogation requiring Miranda safeguards	Not custodial; safeguards not applicable
Reasonableness of backpack search under the Fourth Amendment	State contends search justified and reasonably related in scope	C.D. contends search unreasonable	Search justified and reasonably related in scope

P.M. v. State, 861 N.E.2d 710 (Ind. Ct. App. 2007) (Miranda warnings applicable to custodial context; waiver standards discussed)
G.J. v. State, 716 N.E.2d 475 (Ind. Ct. App. 1999) (school questioning not custodial under Miranda safeguards)
Myers v. State, 839 N.E.2d 1154 (Ind. 2005) (privacy rights for personal property on campus; search considerations)
T.S. v. State, 863 N.E.2d 362 (Ind. Ct. App. 2007) (school security officer actions reviewed for educational purpose standard)
Foster v. State, 633 N.E.2d 337 (Ind. Ct. App. 1994) (strict compliance with Ind. Code §31-32-5-1 for juvenile rights waivers)
Combs v. State, 921 N.E.2d 846 (Ind. Ct. App. 2010) (prima facie error standard in suppression appeals)