State v. Lynn, 2011 Ohio 6404

State v. Lynn involves a Belmont County criminal case where Lynn was indicted for sexual conduct with a child (3/2010 indictment, 10CR15).
Lynn moved to suppress a confession, asserting incompetence to stand trial, involuntariness of the confession, and victim incompetence; the court granted the confession suppression on the knowing/intentional waiver issue.
The trial court found Lynn did not intelligently understand the Miranda waiver due to his mental handicaps and limited intellectual capacity, suppressing the confession.
In the suppression ruling the court relied on Dr. Kristen Haskins’s evaluation, including Grisso testing, to conclude Lynn did not fully comprehend the right to remain silent.
The State appealed, and the Seventh District affirmed the suppression ruling, holding the trial court’s credibility determinations were supported by competent credible evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lynn intelligently waived Miranda rights.	State argues waiver was knowing, intelligent, and voluntary; no need to suppress.	Lynn’s low intellect and mental handicaps prevented intelligent understanding of waiver.	Waiver not intelligent; evidence supports suppression.

Fare v. Michael C., 442 U.S. 707 (1979) (totality-of-the-circumstances test for Miranda waivers)
Colorado v. Connelly, 479 U.S. 157 (1986) (mental condition not alone controlling; coercion needed for involuntariness)
State v. Jenkins, 15 Ohio St.3d 164 (1984) (intelligent waiver assessed under totality of circumstances)
State v. Hall, 48 Ohio St.2d 325 (1976) (factors for assessing understanding of rights)
State v. Frazier, 115 Ohio St.3d 139 (2007) (limits of understanding Miranda rights under totality approach)
State v. Roberts, 110 Ohio St.3d 71 (2006) (deference to trial court on credibility in suppression rulings)
State v. Burnside, 2003-Ohio-5372 (Ohio Supreme Court) (substantive analysis of waiver/voluntariness under Miranda)