State v. Jenkins, 948 N.E.2d 1011

Jenkins was indicted on seven counts of burglary, a third-degree felony, and moved to suppress, which the trial court granted on August 18, 2010.
Oakwood police encountered Jenkins on February 10, 2010; he matched burglary suspect descriptions, was questioned, patted down, and restrained after attempting to flee; he sustained an abrasion during arrest.
Yount interviewed Jenkins at the station, verified Jenkins’s rights, and discussed treatment options in lieu of conviction (TIC) with him.
Jenkins provided oral and written statements on February 11 after a preinterview, while assertions about potential TIC were ongoing; Jenkins sought to suppress later confessions.
The trial court suppressed the February 10 statements, finding Yount’s TIC discussion implied a promise; the court held Jenkins ineligible for TIC by law.
The court ultimately determined that Yount’s false representations undermined Jenkins’s will, leading to suppression of the statements and affirming the suppression order on review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether police promises about treatment affected voluntariness	Jenkins's statements were coerced by false TIC promises	No improper inducement; statements voluntary	Suppression affirmed; TIC promise rendered statements involuntary

Dickerson v. United States, 530 U.S. 428 (U.S. 2000) (voluntariness and Miranda separate free-choice inquiry; coercive police conduct)
Colorado v. Connelly, 479 U.S. 157 (U.S. 1986) (waiver involuntary if will not overborne by coercive police conduct)
State v. Otte, 74 Ohio St.3d 555 (Ohio 1996) (concerning voluntariness and waiver analysis in Ohio)