State v. Moore, 2018 Ohio 1778

On Dec. 25, 2016, Jeremy Foxx was found shot to death; investigation implicated Zachary Wilson as shooter and Allison Moore as present and involved in cleaning and disposing of evidence.
On Dec. 27, 2016, Wilson and Moore were brought to the Warren County Sheriff's Office by Wilson’s mother; Wilson was arrested on a warrant; Moore was briefly handcuffed for safety, patted down, released, left in a training room, and later interviewed.
Moore waived an interview and gave a ~55-minute recorded statement at the sheriff’s office without receiving Miranda warnings; detectives told her she was not under arrest and free to leave.
Moore moved to suppress the statement claiming custodial interrogation (Miranda violation) and involuntariness due to intoxication/withdrawal; the trial court denied suppression after an evidentiary hearing.
Moore entered a no-contest plea to tampering with evidence (third-degree felony) and was sentenced to the statutory maximum of 36 months; she appealed both the denial of suppression and the sentence.
The Twelfth District affirmed: (1) Moore was not in custody for Miranda purposes and her statements were voluntary; (2) the maximum sentence was within statutory authority and supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Moore was in custody such that Miranda warnings were required	State: Moore was not in custody; she voluntarily came to station, was told she was free to leave, and was not restrained during interview	Moore: She was effectively in custody because of initial handcuffing, the station setting, and her subjective fear she could not leave	Held: Not custodial. Court applied objective totality test and found no significant restraint; Miranda not required
Whether Moore's statement was voluntary	State: Statement was voluntary; no coercion, no promises/threats, coherent answers, detectives observed no impairment	Moore: Statement involuntary; she was ill, coming off meth and had taken Xanax, so her capacity was impaired and will overborne	Held: Voluntary. Court found no police overreaching and record showed coherent, detailed responses and no indicia of impairment
Whether trial court erred by imposing maximum 36-month sentence	State: Sentence within statutory range, court considered R.C. 2929.11/2929.12 and factors in PSI and record support maximum	Moore: Court failed to make required findings to impose maximum sentence	Held: No error. After Foster/Mathis, no special findings required; sentencing entry and hearing show consideration of statutory factors and record supports sentence

Miranda v. Arizona, 384 U.S. 436 (defines custodial interrogation requiring warnings)
Oregon v. Mathiason, 429 U.S. 492 (interrogation at station not automatically custodial)
State v. Gumm, 73 Ohio St.3d 413 (objective reasonable-person test for custody)
State v. Otte, 74 Ohio St.3d 555 (voluntariness and police conduct standard)
State v. Edwards, 49 Ohio St.2d 31 (factors for voluntariness analysis)
State v. Marcum, 146 Ohio St.3d 516 (standard of appellate review for felony sentences)