State v. Myer
2017 Ohio 1047
| Ohio Ct. App. | 2017Background
- On Dec. 8, 2015, Jamie Myer, in custody at the Perry County Sheriff’s Office, asked to speak with Sergeant Briggs about becoming an informant and was moved to an interview room.
- Briggs and Myer spoke off-the-record for ~15 minutes before recording was activated; Miranda warnings were not given during the unrecorded portion.
- After recording began, Briggs questioned Myer about two heroin overdoses (T.D. and A.M.); Myer admitted selling heroin to T.D. and later admitted giving A.M. heroin.
- Briggs then read Miranda warnings mid-interview, told Myer he would ask the same topics again, and continued questioning; Myer waived and continued to speak.
- Myer moved to suppress statements; trial court granted suppression of the entire December 8 statements. The State appealed.
- The appellate court affirmed, concluding the midstream Miranda warnings were ineffective under Seibert and related precedent; pre- and post-warning statements were suppressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred by suppressing Myer’s entire statement from Dec. 8, 2015 | Statements were voluntary and not the product of custodial interrogation; Miranda not required for the challenged portions | Briggs interrogated Myer while in custody without Miranda; midstream warnings were ineffective because questioning was a continuous interrogation that elicited incriminating responses | Affirmed: suppression proper — pre-warning interrogation and the subsequent midstream warnings did not render later statements admissible |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishing Miranda warnings and waiver requirements)
- Rhode Island v. Innis, 446 U.S. 291 (defining "interrogation" to include its functional equivalent)
- Missouri v. Seibert, 542 U.S. 600 (holding that "question-first" then warn-midstream technique can render post-warning statements inadmissible; factors to assess effectiveness of midstream warnings)
- Dickerson v. United States, 530 U.S. 428 (recognizing Miranda’s constitutional status)
- J.D.B. v. North Carolina, 564 U.S. 261 (noting custodial setting’s impact on voluntariness and suspect’s perception)
- Ornelas v. United States, 517 U.S. 690 (appellate review standard for mixed questions of law and fact in suppression rulings)
- State v. Burnside, 100 Ohio St.3d 152 (Ohio standard for appellate review of suppression rulings)