State v. CD, 947 N.E.2d 1018

Petitioner-appellant State appeals a trial court order suppressing evidence from a juvenile case.
C.D. was brought to a school office after a report that he appeared under the influence; Vanwanzeele detained him for school purposes.
Richhart, a school security officer and police officer, conducted a drug-influence examination within the office.
The examination lasted about ten minutes and included physical and verbal questioning; afterward the school suspended C.D. and searched his backpack.
The trial court suppressed evidence obtained before meaningful parental consultation; the State moved to dismiss without prejudice; the appellate court reverses and remands.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in suppressing the statements as custodial interrogation	C.D. was not in custodial interrogation; Miranda/§31-32-5-1 safeguards not triggered	C.D. was detained in a school setting and subjected to interrogation like custodial questioning	Not custodial interrogation; Miranda safeguards inapplicable
Whether the trial court erred in suppressing the backpack search as unreasonable	Search justified by C.D.’s apparent impairment and need to find drugs	Search exceeded permissible scope or lacked justification	Search justified; prima facie error acknowledged but reversed; evidence admissible

P.M. v. State, 861 N.E.2d 710 (Ind.Ct.App.2007) (Miranda protections for juveniles; custodial triggers)
G.J. v. State, 716 N.E.2d 475 (Ind.Ct.App.1999) (school officials questioning not custodial interrogation under Miranda)
T.S. v. State, 863 N.E.2d 362 (Ind.Ct.App.2007) (school-related searches and questioning analyzed for educational purpose)
Myers v. State, 839 N.E.2d 1154 (Ind.2005) (juvenile privacy in personal items on campus; reasonableness standard for school searches)
State v. Washington, 898 N.E.2d 1200 (Ind.2008) (standard of review for suppression orders; substantial evidence; no reweighing)