State v. Strickland, 2013 Ohio 2768

Indicted on two counts of aggravated robbery with firearm specifications; juvenile case transferred to common pleas court.
Strickland moved to suppress statements made to police during interrogations.
First interview on June 1, 2011 occurred in a windowless room; Miranda warnings were provided via a pre-interview form.
Second interview on June 3, 2011 occurred in a similar room; guardian not present for June 3 interview.
Trial court found waiver on June 1 valid and statements voluntary; but suppressed post-touch statements from June 3 as involuntary.
Appeals court reverses, holding all June 3 statements were voluntary; remands for proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether June 3 statements were involuntary after the leg contact	State argues coercion/overborne will.	Strickland contends coercive police conduct rendered statements involuntary.	All June 3 statements were voluntary; suppression reversed.

State v. Retherford, 93 Ohio App.3d 586 (2d Dist. 1994) (deference to trial-court factual findings on suppression; legal standard de novo)
State v. Hughes, 2013-Ohio-808 (2d Dist. Montgomery No. 25152) (de novo review for whether facts justify suppression)
State v. Reeves, 2d Dist. Greene No. 2002-CA-9 (2002-Ohio-4810) (deception in interrogation as factor, not per se involuntary)
State v. Stringham, 2d Dist. Miami No. 2002-CA-9 (2003-Ohio-1100) (admonitions to tell the truth permissible; not coercive)
State v. Bailey, 2d Dist. Miami No. 94 CA 39 (1995 WL137019) (cooperation can be considered without rendering confession involuntary)