State v. Trivett
2016 Ohio 8204
| Ohio Ct. App. | 2016Background
- Child (age 3) ingested mother's prescription Wellbutrin; mother Melanie Trivett was the accused.
- Two Medina police detectives came to Trivett’s apartment, insisted on interviewing her at the station, and escorted her there in an unmarked car (one detective sat in back with her).
- At station officers walked her through the building to a basement interview room farthest from exits; in the room officers sat so as to physically block her egress.
- Officers interviewed Trivett for over two hours; at the end they requested she sign authorizations and complete a written statement; she was told she could not leave to complete it.
- Trivett moved to suppress her oral and written statements as obtained in custody without Miranda warnings; trial court denied suppression and a jury convicted her of endangering children.
- Ninth District reversed: trial court’s factual findings were incomplete on custodial aspects; suppression ruling vacated and case remanded for further factfinding on custody/Miranda issues.
Issues
| Issue | Plaintiff's Argument (Trivett) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Trivett was "in custody" for Miranda purposes during the station interview | Police controlled her movements, confined her in a basement room, blocked egress, and compelled completion of a written statement — so she was effectively in custody | The interview was non-custodial; she was not formally arrested and police conduct did not amount to custody | Trial court’s findings were incomplete; appellate court remanded for proper factfinding on custody (suppression denial reversed) |
| Whether trial court’s suppression findings were supported by the record | Trial court omitted material facts (walk through station, location far from exit, seating blocking egress, refusal to let her leave to finish statement) that bear on custody | Trial court relied on some facts that suggested non-custodial interview (no formal arrest, no cage, front seat not separated) | Court held the trial court’s factual findings were incomplete and not supported as a whole; error requiring remand |
| Whether appellate court should decide custody as a matter of law on the record | Trivett argued record demonstrates custody and Miranda error | State argued factual resolution was for trial court and should be upheld | Appellate court declined to resolve custody legally on the record and remanded for trial court to make complete factual findings; did not reach Miranda legal question |
| Effect of reversal on other assignments (weight of evidence) | N/A — suppression error affects admissibility and trial outcome | N/A | Appellate court found other assignments premature and did not address them pending remand |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires Miranda warnings)
- State v. Burnside, 100 Ohio St.3d 152 (2003) (standard of review for suppression: trial court factual findings accepted if supported, legal conclusions reviewed de novo)
- State v. Hopfer, 112 Ohio App.3d 521 (2d Dist. 1996) (trial court is trier of fact at suppression hearing and best suited to assess witness credibility)
- State v. Venham, 96 Ohio App.3d 649 (4th Dist. 1994) (trial court credibility findings given deference)
- State v. McNamara, 124 Ohio App.3d 706 (4th Dist. 1997) (appellate courts independently determine legal conclusions after accepting trial court facts)