State v. Knapp, 2017 Ohio 2808

On June 11, 2015, Deputy Sgt. David Briggs stopped a Pontiac Grand Prix with expired registration after seeing it enter a Circle K; Anthony Knapp was the driver. The passenger fled, was arrested on a felony warrant, and Briggs deployed a K-9 to perform a free-air sniff of the vehicle.
The K-9 alerted to the driver’s side; Briggs had Knapp exit the vehicle, told him the dog had alerted, and then searched the car. Briggs found two small jewelry bags in liquid inside a Polar Pop cup in the center console; Knapp admitted the cup was his and said it contained methamphetamine.
At the time of the initial questioning/interaction, Knapp was not handcuffed, not placed in a patrol car, not told he was detained or not free to leave; Briggs later gave Miranda warnings before a second interview, after which Knapp was arrested.
Knapp moved to suppress his pre-Miranda statements, arguing they were the product of custodial interrogation; the trial court denied the motion. Knapp then pleaded no contest to aggravated possession and tampering and was sentenced to four years of community control and other conditions.
Knapp appealed, arguing the trial court erred by denying the suppression motion because he was in custody when he made statements before receiving Miranda warnings.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Knapp)	Held
Whether Knapp was in custody for Miranda purposes during the initial questioning/search	The stop was an ordinary traffic stop; questioning and the K-9 sniff did not amount to custodial interrogation requiring Miranda	The officer’s actions (ordering him out, K-9 alert, inability to leave for safety) made a reasonable person feel not free to leave, so Miranda warnings were required	Not custodial — trial court properly denied suppression; pre-warning statements admissible

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires Miranda warnings)
Berkemer v. McCarty, 468 U.S. 420 (1984) (ordinary traffic stops are ordinarily noncustodial for Miranda purposes)
Thompson v. Keohane, 516 U.S. 99 (1995) (objective two-part test for Miranda custody: circumstances and whether a reasonable person would feel free to leave)
Pennsylvania v. Bruder, 488 U.S. 9 (1988) (lengthy detention in patrol car and prolonged questioning can convert a stop into custody)
Stansbury v. California, 511 U.S. 318 (1994) (all circumstances must be examined to determine whether a reasonable person would feel free to leave)
Yarborough v. Alvarado, 541 U.S. 652 (2004) (Miranda custody inquiry is objective and does not depend on the suspect’s subjective mindset)
State v. Farris, 109 Ohio St.3d 519 (Ohio 2006) (officer actions like pat-down, taking keys, placing suspect in patrol car can create custody for Miranda purposes)
State v. Mason, 82 Ohio St.3d 144 (1998) (Miranda custody test applies objectively in Ohio)