State v. Campbell
2015 Ohio 3381
Ohio Ct. App.2015Background
- Around 1:00 a.m., Univ. of Dayton police observed Aaron Campbell and two underage females near Campbell’s parked car; an open container was dropped.
- Officer Weber stopped, asked Campbell for ID and age; Campbell said he was 18. Weber then focused on the two females and told Campbell to sit on the sidewalk.
- The two females were arrested for underage consumption; while they were being taken into custody, Officer Weber asked whether Campbell had been drinking.
- Campbell responded that he had "a couple of drinks." He was not given Miranda warnings at any point.
- Campbell was taken to the campus police station and later released to his parents; he was charged with underage consumption and moved to suppress his statements as obtained in custodial interrogation.
- The trial court suppressed the statements, finding Campbell was not free to go; the State appealed and the appellate court reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Campbell was "in custody" for Miranda purposes when he admitted to drinking | State: The encounter was an investigative stop (Terry) and not custodial; Miranda warnings were not required. | Campbell: He was not free to leave, ordered to sit on the ground with officers nearby and multiple officers present, making the encounter custodial. | Reversed: Not in custody; Miranda warnings were not required. |
Key Cases Cited
- Berkemer v. McCarty, 468 U.S. 420 (1984) (ordinary traffic and brief investigative stops are normally noncustodial for Miranda)
- Terry v. Ohio, 392 U.S. 1 (1968) (police may briefly detain for investigation based on reasonable suspicion)
- United States v. Brignoni-Ponce, 422 U.S. 873 (1975) (reasonable suspicion justifies brief detention to investigate)
- Thompson v. Keohane, 516 U.S. 99 (1995) (custody determination is a mixed question of law and fact reviewed independently)
- California v. Beheler, 463 U.S. 1121 (1983) (not all questioning of a suspect is custodial; formal arrest or equivalent restraint required)
- State v. Biros, 78 Ohio St.3d 426 (1997) (Miranda applies only to custodial interrogation)
- State v. Burnside, 100 Ohio St.3d 152 (2003) (appellate review deferential to trial court facts, independent review of legal question)