State v. Verdell, 2018 Ohio 4766

On Dec. 29, 2016, Verdell was indicted for murder, two counts of felony murder, two counts of felonious assault, tampering with evidence, and multiple three-year firearm specifications after Stephan Shyne was found shot to death in a vehicle.
Police found Verdell walking a few blocks from the crash scene, wearing black and with blood and facial scratches; Officer Stewart handcuffed him, placed him in the patrol car for officer safety and medic evaluation, and did not Mirandize him at that time.
While handcuffed in the cruiser and being seen by a medic, Verdell made spontaneous statements (in response to innocuous questions) including "I shot him," which Stewart later relayed; Verdell was then taken to the hospital.
Approximately three hours after being found and after hospital discharge, Detective Roberts Mirandized Verdell using a written form, Verdell signed a waiver, and gave a detailed inculpatory statement to Roberts admitting the shooting and disposal of the gun.
Verdell moved to suppress: (1) the statements made in the cruiser for lack of Miranda warnings and (2) the station-house statement for an involuntary/invalid Miranda waiver; the trial court denied suppression, Verdell pleaded no contest, and was sentenced to an aggregate 18 years to life.

Issue	State's Argument	Verdell's Argument	Held
Whether statements made in the cruiser required Miranda warnings	Officer questions were non-interrogative on-scene factfinding; not custodial interrogation	Statements were made while handcuffed and in custody and thus required Miranda warnings	Court held no Miranda required: questions were not the kind police should have known would elicit an incriminating response; not custodial interrogation requiring warnings
Whether Verdell validly waived Miranda before the station-house interview	Written and oral warnings given; Verdell signed waiver; he was lucid and not so impaired by injury/intoxication as to negate voluntariness	Waiver involuntary because of injuries and intoxication; could not knowingly/ intelligently waive rights	Court held waiver knowing, intelligent, voluntary based on totality: written waiver, coherent behavior on video, no coercion or threats

Miranda v. Arizona, 384 U.S. 436 (establishing Miranda warnings for custodial interrogation)
Moran v. Burbine, 475 U.S. 412 (State bears burden to prove knowing, intelligent, voluntary waiver)
Rhode Island v. Innis, 446 U.S. 291 (defines interrogation as words or actions police should know likely to elicit incriminating response)
Oregon v. Mathiason, 429 U.S. 492 (Miranda applies when restraint on freedom comparable to formal arrest)
State v. Biros, 78 Ohio St.3d 426 (Miranda required only for custodial interrogation)
State v. Belton, 149 Ohio St.3d 165 (written/oral waiver is strong proof of valid Miranda waiver)