State v. Madden, 2022 Ohio 2638

Keajzuan Madden was indicted for aggravated burglary with two firearm specifications.
He was Mirandized, signed a rights acknowledgement, and initially denied involvement during a recorded stationhouse interview.
Detectives left Madden alone for ~55 minutes, then returned and used aggressive statements (citing co‑defendant cooperation and consequences) and urged him to tell his side.
Madden asked for a lawyer multiple times; detectives told him they did not have time to wait and that he would be jailed and could get an attorney later.
After additional questioning and being asked whether he wanted an attorney or to talk, Madden responded "Alright," sat down, and then confessed.
The trial court suppressed Madden’s statements as obtained in violation of his invoked right to counsel; the state appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Madden waived his right to counsel by initiating further communication after requesting counsel	Madden’s question about the penalty after detectives left showed he initiated discussion and thus waived his right	Madden repeatedly invoked counsel; his post‑invocation question was prompted by detectives’ repeated invitations and threats, not an unprompted initiation	Court: No waiver. Invocation was unequivocal; detectives reinitiated interrogation and elicited the confession, so statements suppressed
Whether detectives’ conduct after invocation constituted prohibited interrogation	State: detectives’ comments were permissible (routine custodial conversation)	Defense: detectives’ repeated invitations and references to cooperating witnesses and severe penalties were calculated to elicit incriminating responses	Court: Conduct was interrogation under Innis/Bradshaw/Edwards; police improperly reinitiated questioning after request for counsel

Arizona v. Roberson, 486 U.S. 675 (police may not interrogate a suspect who has invoked the right to counsel unless the suspect initiates further communication)
Edwards v. Arizona, 451 U.S. 477 (once counsel is requested, interrogation must cease until counsel is provided or the suspect initiates further contact)
Oregon v. Bradshaw, 462 U.S. 1039 (defendant must initiate further communication and knowingly waive right to counsel)
Rhode Island v. Innis, 446 U.S. 291 (definition of "interrogation" as words or actions reasonably likely to elicit incriminating response)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings requirement)
State v. Knuckles, 65 Ohio St.3d 494 (Ohio adopts bright‑line rule: questioning must stop after request for counsel)
State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression rulings)
State v. Van Hook, 39 Ohio St.3d 256 (police may not reinitiate interrogation under guise of generalized discussion)