State v. Casteel, 2017 Ohio 8303

Miranda Casteel was stopped on a public sidewalk after a report of a woman looking into car windows; an officer questioned her near his cruiser and asked to search her purse.
Casteel consented to the search; officer found two pills later identified as Ritalin without a prescription.
Casteel was not handcuffed, not placed under arrest, and was told she was free to leave; she later gave a recorded statement at the Rite Aid store where the car had been parked.
Casteel moved to suppress all evidence claiming she was detained and interrogated without Miranda warnings; the trial court denied the motion.
She pleaded no contest to aggravated possession of drugs and appealed, raising (1) denial of the suppression motion (Miranda/custody/consent) and (2) admission of the post‑stop audio recording.

Issue	State's Argument	Casteel's Argument	Held
Whether Casteel was "in custody" requiring Miranda warnings, so that statements or evidence should be suppressed	Miranda warnings are not required for consensual investigatory encounters or to validate a consent search; she was not in custody	She was not free to leave, so custodial interrogation occurred and Miranda should have been given; any evidence tied to statements should be suppressed	Court held she was not in custody under the totality of circumstances; no incriminating statements were used, and Miranda was not triggered
Whether the trial court abused discretion by admitting the post‑stop audio recording at the suppression hearing	Rules of Evidence do not apply to suppression hearings; the recording was relevant to the totality of circumstances	Recording was irrelevant to suppression (it occurred after the encounter) and more prejudicial than probative	Court found no abuse of discretion: recording was admissible at the suppression hearing and relevant to assessing custody

Miranda v. Arizona, 384 U.S. 436 (establishing Miranda warnings requirement for custodial interrogation)
Michigan v. Mosley, 423 U.S. 96 (statements made in absence of Miranda inadmissible)
Berkemer v. McCarty, 468 U.S. 420 (routine investigatory stops ordinarily not custodial for Miranda purposes)
Schneckloth v. Bustamonte, 412 U.S. 218 (voluntary consent to search does not require knowledge of right to refuse)
State v. Farris, 849 N.E.2d 985 (Ohio Supreme Court: Miranda/Article I protections and suppression of statements obtained in custody without warnings)
State v. Robinette, 685 N.E.2d 762 (Ohio Supreme Court: officers need not inform detainees they are free to go before seeking consent)
State v. Burnside, 797 N.E.2d 71 (appellate review standard for motions to suppress)