State v. Prescott
2012 ME 96
| Me. | 2012Background
- Prescott appealed after a conditional guilty plea to OUI and failure to report an accident; suppression motion based on custodial interrogation without Miranda warnings was denied; conviction followed a later suppression ruling; the police questioned Prescott at her home and then at the accident scene; she was not given warnings prior to interrogation; the court found custody at the scene but not at the home; the appeal challenges custodial status and admissibility of statements.
- Police investigated a single-vehicle accident; Prescott was identified as the operator; officers went to Prescott’s home to locate her and brought her to the scene without Miranda warnings.
- Prescott was transported involuntarily from her home to the accident scene for questioning; she was not handcuffed but was not free to leave during questioning.
- Kaminski questioned Prescott at the scene about alcohol and the accident; his questioning followed Gilliam’s initial encounter and directed Prescott to accompany him.
- Interrogation at the scene lasted about thirty minutes; the court concluded custody existed and statements were not admissible absent Miranda warnings; the suppression order was partially vacated on appeal.
- The State’s contentions framed the scene as a Terry stop; the court concluded the circumstances amounted to custody requiring Miranda warnings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Prescott was in custody for Fifth Amendment purposes during questioning | Prescott was in custody | Not in custody; Terry stop | Custody existed; statements suppressed at scene |
Key Cases Cited
- State v. Poblete, 2010 ME 37 (Me. 2010) (custody standard; de novo review on custody decision; preponderance burden on State)
- State v. Dominique, 2008 ME 180 (Me. 2008) (Miranda warnings scope; custody analysis)
- State v. Williams, 2011 ME 36 (Me. 2011) (Miranda rights requirement; custodial interrogation)
- State v. Dion, 2007 ME 87 (Me. 2007) (multifactor custody test; totality of circumstances)
- State v. Holloway, 2000 ME 172 (Me. 2000) (objective custody determination; lack of subjective entitlement)
- State v. Gulick, 2000 ME 170 (Me. 2000) (definition of detention vs. stop; proximity to custody)
- Donatelli, 2010 ME 43 (Me. 2010) (Terry stop framework and limited intrusion)
- State v. Lavoie, 562 A.2d 146 (Me. 1989) (custody and self-incrimination protections)