State v. Taste, 2021 Ohio 3286

Ohio State Highway Patrol troopers observed a Dodge Durango with very dark tint and a rental sticker commit a marked-lane violation on I-70 and initiated a traffic stop.
When a trooper approached and knocked on the driver’s window, the driver (Damrick Taste) sped away, triggering a multi-jurisdictional vehicle pursuit that ended in a crash; occupants fled and were soon arrested.
Taste was Mirandized at the scene, acknowledged understanding his rights, was silent to initial questioning, and was transported to the patrol post.
Approximately one to two hours later a different trooper questioned Taste at the post; Taste answered and admitted he was the driver during the chase.
Taste was indicted for failure to comply and moved to suppress his post-arrest statements, arguing he had invoked his Fifth Amendment right to remain silent and that subsequent questioning violated Miranda and Mosley; the trial court denied suppression and the denial was appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Taste unequivocally invoked his right to remain silent	State: Taste did not unambiguously invoke; initial silence does not equal invocation	Taste: His silence and lack of continued questioning show he invoked his right and police should have stopped	Court: Taste never made an unequivocal invocation; initial silence was ambiguous, so officers could continue investigation
Whether Taste’s later statements constituted a valid waiver of Miranda rights	State: Taste knew and acknowledged his rights and voluntarily answered some questions, implying waiver	Taste: Any later responses were after an invocation and without proper waiver or fresh warnings	Court: Totality of circumstances support an implied, voluntary waiver; statements admissible
Whether police had to re-Mirandize under Mosley before the later questioning	State: No; only ~1–2 hours elapsed, Taste remained in custody and aware of rights	Taste: Officers should have given fresh warnings before re-interrogation per Mosley	Court: No fresh warnings required; Roberts factors show Taste remained aware of rights and re-warning unnecessary

Berghuis v. Thompkins, 560 U.S. 370 (implied waiver may be inferred from uncoerced statements)
North Carolina v. Butler, 441 U.S. 369 (Miranda waiver need not be written or express)
Michigan v. Mosley, 423 U.S. 96 (permissible to reinitiate questioning after invocation only if proper safeguards applied)
State v. Edwards, 49 Ohio St.2d 31 (totality-of-the-circumstances factors for waiver)
State v. Murphy, 91 Ohio St.3d 516 (invocation of right to remain silent must be clear and unambiguous)
State v. Roberts, 32 Ohio St.3d 225 (factors to assess whether re-warning is required)
State v. Powell, 132 Ohio St.3d 233 (awareness of rights can persist over time; re-warning not always necessary)