State v. Edwards, 299 Conn. 419

Lee Edwards was convicted of first-degree manslaughter, first-degree assault, and risk of injury to a child; capital felony murder was acquitted.
Defendant challenged the admission of statements made to police before arrest, arguing Miranda violations and noncompliance with videotaping requirements.
Facts show the victim died after being punched with boxing gloves on; D observed the events and transported the victim to the hospital where death was pronounced.
At hospital and later at the police station, Edwards was told he could leave and that his presence was voluntary; he signed a waiver and gave a written voluntary statement.
Trial court denied suppression after determining Edwards was not in custody for Miranda purposes; conviction followed.
On appeal, the court reaffirmed the objective custody standard and declined to adopt a subjective standard incorporating Edwards’s mental impairments; it also rejected a constitutional videotaping mandate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements were admissible under Miranda if made before arrest	Edwards was not in custody; Miranda rights not attached.	Statements obtained in custody before arrest violated Miranda.	Not in custody; Miranda did not attach; statements admissible.
Whether mental impairments require a subjective custody approach	Subjective factors should influence custody due to Edwards’s impairments.	Court should consider Edwards’s mental state in determining custody.	Court refused subjective approach; retained objective reasonable-person standard.
Whether videotaping of custodial interrogations is constitutionally required	Statutory and constitutional mandate favors recording confessions.	Recording would improve reliability and prevent false confessions given Edwards’s impairments.	No constitutional or statutory tape-recording requirement for custodial interrogations.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (mandatory warnings for custodial interrogations)
California v. Beheler, 463 U.S. 1121 (U.S. 1983) (custody inquiry based on objective circumstances)
State v. Britton, 283 Conn. 598 (Conn. 2007) (objective reasonable-person custody standard; unsigned custody indicators)
State v. Turner, 267 Conn. 414 (Conn. 2004) (rejects subjective youth/experience considerations in custody analysis)
Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004) (clarifies separation of Miranda custody from subjective factors like age/experience)
State v. Pinder, 250 Conn. 385 (Conn. 1999) (applies objective custody standard despite mental limitations)
State v. Lockhart, 298 Conn. 537 (Conn. 2010) (no constitutional recording requirement for custodial interrogations)