State v. Marejka, 2018 Ohio 2570

In Nov. 2015 Dayton PD investigated a pregnancy of a 13-year-old who identified Jaquaise Marejka as the father. Detective Lindsey Delaney arranged an interview with Marejka via his probation officer.
On Feb. 24, 2016 Marejka voluntarily appeared at the Dayton Safety Building and was interviewed for ~30 minutes; the interview room door was not locked and he was not handcuffed.
Delaney informed Marejka at the start that he did not have to talk, was free to leave, and could consult an attorney; she completed a pre-interview rights form and Marejka initialed/acknowledged each right and later consented to a cheek swab.
Marejka was later indicted for rape (victim under 13). He moved to suppress statements from the interview, claiming coercion and invalid Miranda waiver.
The trial court denied the suppression motion; Marejka pleaded no contest to rape (force/threat) and received a mandatory 10-year term and Tier III sex offender classification.
On appeal the Second District affirmed, finding no custodial interrogation and, alternatively, that any waiver was knowing, voluntary, and not the product of coercion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the interview was a custodial interrogation requiring Miranda warnings	State: Not custodial — Marejka voluntarily came, was told he was free to leave, interview short, no restraints	Marejka: Felt compelled by police/probation threats of arrest; thus was effectively in custody	Court: Not custodial; reasonable person would not feel under arrest, so Miranda not required
Whether statements were coerced or constituted an invalid Miranda waiver	State: Even if custodial, Delaney gave warnings and Marejka knowingly, intelligently, voluntarily waived rights; no coercion	Marejka: Coerced by alleged threats of a warrant; limited education meant he could not understand/waive rights	Court: No coercion shown; videotape and form show understanding and waiver; waiver was voluntary, knowing, and intelligent

Miranda v. Arizona, 382 U.S. 436 (establishes Miranda warnings and waiver requirements)
Moran v. Burbine, 475 U.S. 412 (waiver must be voluntary, knowing, and intelligent)
State v. Biros, 78 Ohio St.3d 426 (custody test: formal arrest or restraint on freedom of movement)
State v. Burnside, 100 Ohio St.3d 152 (standard of appellate review for suppression—mixed question of law and fact)
California v. Beheler, 463 U.S. 1121 (custodial interrogation inquiry—degree of restraint associated with formal arrest)
Oregon v. Mathiason, 429 U.S. 492 (noncustodial confession where suspect free to leave)
State v. Dailey, 53 Ohio St.3d 88 (Ohio discussion of voluntariness and waiver of Miranda rights)