State v. Harris, 874 N.W.2d 602

Officers responded to reports of metal clinking from a dark, allegedly vacant townhouse; they found Harris hiding in the basement.
Harris was handcuffed “almost immediately,” questioned briefly in the basement about his identity and why he was there, and officers observed burglary tools and removed him to a squad car.
In the squad car, while officers were occupied and not questioning him, Harris volunteered statements about homelessness, entering vacant houses to sleep, and taking copper to sell for food.
Harris was later brought, unhandcuffed, to the county jail where Detective Buchanan asked if he would come to the detective bureau for an interview; Harris replied, "I got caught, man, there's nothing else to say."
Harris moved to suppress both sets of statements as the product of custodial interrogation without Miranda warnings; the circuit court denied suppression, a jury convicted Harris, and he appealed.

Issue	Harris's Argument	State's Argument	Held
Whether Harris's squad-car statements must be suppressed as the fruit of unwarned custodial interrogation in the basement	The squad-car statements flowed directly from unlawful custodial interrogation in the basement and were not sufficiently attenuated	Though the basement questioning was an unwarned custodial interrogation, the later squad-car statements were sufficiently attenuated by intervening circumstances	Admitted: Court found attenuation sufficient (temporal gap, intervening acts, lack of officer bad faith)
Whether Harris's jail remark required Miranda warnings because it was elicited by Detective Buchanan	The remark was the product of custodial interrogation (no Miranda given) and should be suppressed	The detective’s question was a procedural invitation to agree to an interview, not interrogation likely to elicit incriminating statements, so Miranda was not required	Admitted: Detective’s communication was not ‘‘interrogation’’ under Innis; Miranda warnings not required

Miranda v. Arizona, 384 U.S. 436 (establishing Miranda warnings for custodial interrogation)
Rhode Island v. Innis, 446 U.S. 291 (defining "interrogation" as words or actions reasonably likely to elicit an incriminating response)
State v. Anderson, 165 Wis. 2d 441 (discussing attenuation factors: temporal proximity, intervening circumstances, and purpose/flagrancy of misconduct)
State v. Armstrong, 223 Wis. 2d 331 (placing burden on State to prove custodial interrogation standards)
State v. Artic, 327 Wis. 2d 392 (attenuation analysis and assessing temporal/intervening factors)
United States v. Conrad, 673 F.3d 728 (7th Cir.) (observing no fixed temporal rule for attenuation)