This appeal pertains to whether a suspect’s admission at a police station should have been suppressed due to being made during a custodial interrogation without Miranda warnings being followed.
Facts of the Case
A four-year-old child told her mother that while she was outside their apartment an unknown man had grabbed and molested her. In a CJC interview the child further described the man as wearing glasses, a blue shirt, and blue pants. Police learned from a neighbor that a man matching this description had slowly driven through the apartment complex recently, in a two-door, maroon car. Police later identified Schaefer as the owner of this type of vehicle, and obtained a warrant for Schaefer’s DNA.
A detective served the warrant at Schaefer’s home, and informed him the DNA collection would take place at the police station. Schaefer consented to the warrant, however he was handcuffed while the officer drove to the station. Schaefer was placed in an interview room, where two armed officers took samples of Schaefer’s blood and saliva. The handcuffs were removed during the testing, but remained attached to Schaefer by a waist belt. After the testing the detective told Schaefer that he was the subject of an investigation and read him his Miranda rights. Schaefer responded by saying, “Yeah. I think I will—I will need a lawyer.” The detective, however, continued speaking until Schaefer eventually disclosed that he had been in the area looking for apartments on the day of the assault. Before trial, the court denied Schaefer’s motion to suppress this statement, and he was convicted by a jury.
Issue on Appeal
Schaefer argued on appeal that the trial court erred in denying his motion to suppress on the grounds that was not yet in custody for Miranda purposes when the statement was made. Before both the trial court and court of appeals it was undisputed that the detective’s conversation with Schaefer was an interrogation. The issue remained whether Schaefer was already in custody when the interrogation took place.
Reasoning
The Court noted that in the context of Miranda, ‘custody’ indicates circumstances that present a “serious danger of coercion.” To determine whether a suspect is in a custodial environment, courts first look to whether a reasonable person would feel they were free to end the interrogation and leave. Several of the relevant factors here include the fact that Schaefer was transported to the station by police, and placed in a waist belt and handcuffs. The handcuffs remained attached to the belt throughout the entire encounter with police. Each police officer and detective that Schaefer interacted with was armed, and the door to the interrogation room was closed throughout the encounter. At a minimum, Schaefer would not have been able to leave without the waist belt and handcuffs first being removed.
Even with a finding that Schaefer was in custody and the interrogation should have been stopped when he requested an attorney, the trial court’s decision was not required to be reversed if their error was harmless and inconsequential. During Schaefer’s jury trial his admission to being present at the apartment complex on the day of the assault was critically relevant. The DNA found on the child after the assault could only be identified as “male DNA,” but could not be linked to a specific person. The State’s additional evidence regarding the description of Schaefer’s appearance and his vehicle was relatively circumstantial.
Conclusion
Because Schaefer was in custody when the interrogation took place, the interaction should have ended when he invoked his right to an attorney. Schaefer’s admission to being present at the apartment complex on the day of the assault was crucial to the state’s case and ought to have been suppressed at trial. The Court of Appeals remanded Schaefer’s case for a new trial, ordering his incriminating statement be suppressed.