State v. Reed, 2016 Ohio 7416

In Nov. 2014 Brandon Reed was found unconscious at home; medics administered Narcan and transported him to Miami Valley Hospital — Jamestown (a stand‑alone ED).
Officer Estep arrived at the hospital ~34 minutes after leaving scene, entered Reed’s treatment room after ~15–20 minutes, advised Reed he was investigating the loss of consciousness, and gave Miranda warnings.
Reed appeared lucid; two officers testified he was alert, oriented, not slurring, and understanding of rights. Reed signed a medical‑records release in Estep’s presence; an officer completed the form and sent it to the hospital.
Reed was indicted for possession of heroin and moved to suppress his statements and the hospital records, arguing he lacked capacity to consent after the overdose. He also filed a motion in limine to exclude medical records for chain/ testing defects.
The trial court overruled the suppression motion, reserved ruling on the motion in limine, and ordered the parties to submit the medical records. Reed pleaded no contest before the court ruled on the in limine motion and was sentenced.
On appeal, the court affirmed, finding competent credible evidence supporting voluntary waiver and concluding the in limine issue was not preserved because the trial court made no final ruling before the plea.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Reed)	Held
Whether Reed’s Miranda waiver and signed medical‑release were knowing and voluntary	Officers observed Reed lucid and oriented; testimony and a medical note support capacity — waiver valid and records identified	Reed was recovering from heroin overdose and lacked capacity to understand rights or validly consent to release	Court: Waiver and release were valid; competent, credible evidence supports trial court’s finding
Whether trial court abused discretion by admitting medical records (motion in limine)	Ruling not reviewable because trial court reserved decision and no final ruling occurred before plea	Records should be excluded for noncompliant testing and lack of independent analysis; motion in limine should have been decided pre‑plea	Court: Issue not preserved — no final ruling to review since the court deferred until records were submitted; assignment overruled

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation)
Edwards, 49 Ohio St.2d 31 (totality of circumstances test for waiver)
Treesh, 90 Ohio St.3d 460 (trial court as factfinder on suppression hearings)
Dunlap, 73 Ohio St.3d 308 (appellate deference to trial court factual findings)
DeHass, 10 Ohio St.2d 230 (credibility determinations are for the factfinder)
Long, 127 Ohio App.3d 328 (suppression review involves mixed questions of law and fact)