State v. Mattheisen, 359 P.3d 1218

Defendant convicted of first-degree sexual abuse under ORS 163.427; appeal challenges suppression of inculpatory statements made without Miranda warnings.
Initial interview with defendant occurred October 14, 2011 at police station; M had alleged defendant touched her vaginal area years earlier.
Detective Kirkpatrick confronted defendant without Miranda warnings and offered a private polygraph with a former police officer as examiner.
Polygraph testing occurred about two hours, with recording; examiner deemed defendant deceptive on sexual-abuse questions.
Final interview, about 50 minutes, followed the polygraph; defendant again was not Mirandized; officers encouraged truth-telling and emphasized two possible offender groups.
After the interview, defendant admitted touching M’s vagina; arrest followed in the testing office; trial court denied suppression; appeal led to reversal and remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether compelling circumstances existed requiring Miranda warnings	State: no compelling circumstances; Miranda not required	Defendant: circumstances were compelling; Miranda warnings required	Compelling circumstances existed; suppression error
Role of location in determining compelling circumstances	State: office setting neutral; not police-dominated	Defendant: unfamiliar, police-associated, polygraph context created coercive atmosphere	Location contributed to compelling circumstances
Impact of polygraph and questioned presumptions of guilt on coercion	State: polygraph not coercive; questioning was non-coercive	Defendant: repeated assertions of guilt and reliance on polygraph pressured confession	Polygraph-based pressure supported coercive atmosphere
Whether defendant could end the interrogation	State: defendant could have left; he nodded at arrest but could have ended encounter	Defendant: reasonable person would be compelled to answer; placed in police-dominated setting	Ability to end the encounter did not negate coercive atmosphere

State v. Shaff, 343 Or 639 (2007) (miranda warnings analysis for totality of circumstances)
State v. Roble-Baker, 340 Or 631 (2006) (police-dominated atmosphere factors in compelling circumstances)
State v. Northcutt, 246 Or App 239 (2011) (nonexclusive four-factor test for compelling circumstances)
State v. Machain, 233 Or App 65 (2009) (repeated coercive interrogation tactics and implied guilt analysis)
State v. Nunez, 243 Or App 246 (2011) (additional factors like demeanor, number of officers, confinement)
State v. Shirley, 223 Or App 45 (2008) (compelling circumstances framework reliance)
State v. Ford, 244 Or App 289 (2011) (officer's repeated commands and implications of guilt create coercive overtones)