State v. Soto
2017 Ohio 4348
Ohio Ct. App.2017Background
- Vittorio Soto was indicted for two counts of rape of a child under ten after giving a videotaped confession during an interview at the Lorain Police Department.
- Detective Tabitha Angello conducted the interview; Soto moved to suppress his statements on Miranda and inducement grounds, arguing he was not advised of Miranda warnings and his confession was prompted by promises.
- The trial court found Soto was in custody and entitled to Miranda warnings, granted the suppression motion, but concluded the confession was not the product of promises.
- The State appealed, arguing (1) some factual findings lacked competent support and the trial court omitted pertinent facts, (2) the trial court applied incorrect legal standards by considering subjective perceptions, and (3) the custody determination was erroneous.
- The appellate court reversed, holding the trial court’s factual findings were incomplete and that it had applied an improper mix of subjective and objective standards, and remanded for further factual findings and proper legal analysis.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Soto) | Held |
|---|---|---|---|
| Adequacy/support for trial court factual findings | Some findings (e.g., detective uniform) lack competent, credible evidence; other facts were supported but omitted | Trial court findings were sufficient or omitted facts were not material; appellate court can review video | Trial court’s finding that detective wore a police uniform is supported, but overall findings are incomplete because many pertinent facts were omitted; remand required |
| Legal standard for custody (objective vs. subjective) | Trial court improperly relied on subjective elements; custody is an objective reasonable-person test | Trial court permissibly considered detainee’s perspective; some correct legal statements were made | Trial court applied incorrect law by considering the defendant’s subjective thoughts and mixing standards; error required remand |
| Whether interview was custodial (Miranda required) | Trial court wrongly found Soto would not have felt free to leave; State challenges custody holding | Soto argues he was not free to leave and therefore Miranda required | Moot on appeal because appellate court sustained errors in findings and legal standard and remanded without resolving custody on merits |
| Whether confession was induced by promises | State argues confession voluntary and not induced; trial court found no inducement | Soto argued direct/indirect promises induced confession | Trial court found no inducement; appellate opinion did not disturb that factual conclusion but remanded for further factual findings and correct legal analysis |
Key Cases Cited
- State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of review for suppression: trial court resolves facts, appellate court reviews law de novo)
- State v. Mills, 62 Ohio St.3d 357 (1992) (trial court as factfinder in suppression hearings)
- State v. Fanning, 1 Ohio St.3d 19 (1982) (deference to trial court findings when supported by competent, credible evidence)
- California v. Beheler, 463 U.S. 1121 (1983) (custody requires formal arrest or restraint on freedom of movement associated with arrest)
- Oregon v. Mathiason, 429 U.S. 492 (1977) (custody analysis principles)
- Thompson v. Keohane, 516 U.S. 99 (1995) (two-step custody inquiry: circumstances then objective reasonable-person test)
- Hoffner v. State, 102 Ohio St.3d 358 (2004) (application of objective standard for custody under Ohio law)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (custody inquiry focuses on how a reasonable person in the suspect’s position would have understood the situation)