State v. Matthew A. Lonkoski, 2013 WI 30

Defendant Lonkoski was investigated after his infant daughter Peyton died from an overdose; autopsy showed morphine and hydromorphone in Peyton's system.
Question presented: whether statements made during police interrogation were admissible given Lonkoski's prior statement asking for an attorney and whether he was in custody for Miranda purposes.
Circuit court initially suppressed statements after the attorney request (Edwards violation) but then denied suppression after reconsideration, finding no custody when the request was made.
Court of Appeals affirmed the denial of suppression on different grounds, assuming custody at the time of the request and upholding admissibility under Edwards reinitiation.
Wisconsin Supreme Court granted review to resolve whether Lonkoski was in custody when he stated he wanted an attorney, thus controlling the Miranda/Edwards analysis.
Court holds Lonkoski was not in custody when he first asked for an attorney; Miranda and Edwards do not apply to suppress the subsequent statements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Lonkoski in custody when he asked for an attorney?	Lonkoski was in custody due to focused investigation and demeanor.	Lonkoski was not in custody; he could leave and was not restrained.	Not in custody; Miranda does not apply.
If not custody, whether Edwards reinitiation analysis is needed for admissibility of later statements	Edwards analysis governs admissibility after reinitiation following a custodian invocation.	Edwards should apply if custody existed or if interrogation was imminent.	Unnecessary to decide Edwards reinitiation; custody not established, so Edwards not triggered.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes custodial interrogation rule and required warnings)
Edwards v. Arizona, 451 U.S. 477 (1981) (limits interrogation after invoking right to counsel unless reinitiated)
Stansbury v. California, 511 U.S. 318 (1994) (objective custody determination based on totality of circumstances)
State v. Martin, 343 Wis. 2d 278 (2012) (totality of circumstances test for custody; factors include freedom to leave)
State v. Koput, 142 Wis. 2d 370 (1988) (establishes objective custody standard in Wisconsin)
State v. Leprich, 160 Wis. 2d 472 (Ct. App. 1991) (arrest/restraint framework in custody analysis)
State v. Grady, 317 Wis. 2d 344 (2009) (interrogation context and custody considerations)
State v. Hambly, 307 Wis. 2d 98 (2008) (imminent interrogation/custody distinctions in Edwards context)
McNeil v. Wisconsin, 501 U.S. 171 (1991) (comments on invocation rights outside custodial context)
Lange v. Lange, 317 Wis. 2d 383 (2009) (probable cause and warrantless arrest standards for custody analysis)
Hassel v. State, 2005 WI App 80 (2005) (initial custody determinations in Wisconsin appellate context)