State v. Schiessler, 2012 Ohio 4085

Defendant-appellant Justin S. Schiessler was arrested in December 2010 and interrogated at the Dayton Safety Building by Detective David Hirst.
Schiessler signed a Pre-Interview Rights form after the detective explained and read each Miranda right and the waiver of rights portion, and he read the waiver aloud.
The interview lasted about 1.5 hours with breaks; Schiessler was not handcuffed, not under the influence, and gave two written statements.
Schiessler, 18 at the time, had completed nine years of schooling; the record does not establish that he was still in school.
Schiessler was charged with four counts (two aggravated robbery, two felonious assault), moved to suppress the statements, and the trial court denied the motion after accepting Detective Hirst’s testimony as credible.
Schiessler pled no contest to all counts; the trial court sentenced him to ten years on each aggravated robbery conviction, with concurrent terms; the appellate court affirmed the suppression ruling and conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the Miranda waiver knowingly and voluntarily given?	Schiessler argues the waiver was involuntary due to youth/education.	State contends Hirst established understanding and voluntariness.	Waiver knowingly and voluntarily established.
Was trial counsels’ failure to present mental-deficiency evidence ineffective assistance?	Schiessler asserts counsel should have offered evidence of mental deficiencies.	Record shows no evidence of mental deficiencies; counsel not ineffective.	No ineffective-assistance finding; record unsupported.

Tague v. Louisiana, 444 U.S. 469 (U.S. 1980) (limits of cognitive understanding evidence for Miranda waiver)
Oregon v. Elstad, 470 U.S. 298 (U.S. 1985) (ramifications of subsequent statements after proper warnings)
State v. Lail, 2011-Ohio-2312 (Ohio 2d Dist 2011) (discusses mental deficiency evidence and waiver analysis)