State v. Knight
2011 Ohio 3284
Ohio Ct. App.2011Background
- Knight was convicted after a no-contest plea for Forgery in violation of R.C. 2913.31(A)(3).
- Police stopped Knight after a counterfeit $50 bill was alleged to have been passed at the Thunderbowl in Englewood; Knight was identified as the driver of a white Mercury.
- Knight admitted she had been at the Thunderbowl and claimed a friend gave her a $50 bill to buy drinks.
- Knight was arrested after officers were advised by a detective; Miranda warnings were administered following arrest, and she was not questioned at that time.
- Knight moved to suppress the statements made to Tharp; the trial court overruled the motion; she pled no contest and was sentenced to community control.
- The sole issue on appeal was whether Knight was in custody during interrogation such that Miranda warnings were required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Knight in custody for Miranda purposes during interrogation? | State contends custody existed, requiring warnings. | Knight contends she was in custody and Miranda warnings were required. | Not custodial; Miranda warnings not required prior to arrest. |
Key Cases Cited
- State v. Biros, 78 Ohio St.3d 426 (1997) (defines custodial interrogation standard for Miranda)
- Terry v. Ohio, 392 U.S. 1 (1968) (investigatory stop not a custodial arrest)