State v. Muntean
12 A.3d 518
Vt.2010Background
- Investigation opened December 2007 into alleged sexual abuse of defendant's children and grandchildren; D spoke with the detective at a Rutland state police barracks interview on January 3, 2009; interview occurred in a small, windowless polygraph room in a secured police area with the door closed; no Miranda warnings were given at any time and D was not told he could leave at will; D admitted some acts with his adult daughters but denied others involving the grandsons; the interview lasted about one hour and culminated with D being cited to appear in court and then leaving the barracks after fingerprints and photos were taken; trial court suppressed all statements, concluding custody for Miranda purposes was present throughout.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Muntean in custody for Miranda purposes during the interview? | State contends the interview was custodial. | Muntean argues not custodial for all or part of interview. | Custody for the entire interview; Miranda warnings required. |
| Did the absence of Miranda warnings mandate suppression of all statements? | State relies on custodial interrogation framework. | Muntean asserts statements should be admissible if noncustodial. | Yes, suppression upheld due to custodial interrogation. |
| What governing standard applies to custody determinations? | Federal standard governs; totality of circumstances. | Weighs factors differently under state precedent. | Court applies totality-of-circumstances and de novo review of custody. |
Key Cases Cited
- Oregon v. Mathiason, 429 U.S. 492 (1977) (noncustodial station-house questioning not per se custodial)
- Miranda v. Arizona, 384 U.S. 436 (1966) (established warnings for custodial interrogation)
- Stansbury v. California, 511 U.S. 318 (1994) (focus on objective circumstances to assess custody)
- Beheler et al., 463 U.S. 1121 (1983) (location alone not dispositive; custody depends on totality)
- Pontbriand, 178 Vt. 120, 878 A.2d 227 (2005 VT) (fact-specific custody analysis in Vermont; multi-factor inquiry)
- Oney, 187 Vt. 56, 989 A.2d 995 (2009 VT) (noncustodial where voluntariness and leave-rights are clear)
- Hohman, 136 Vt. 341, 392 A.2d 935 (1978) (consideration of whether person reasonably believes not free to leave)
- Brunell, 150 Vt. 388, 554 A.2d 242 (1988) (voluntary invitation to station can still yield custody if coercive)