Idaho v. Huffaker
Annotate this CaseOn July 12, 2014, around 5:00 A.M., Ben Savage appeared at the Custer County Sheriff’s Office and reported that defendant-respondent Jon Huffaker had pointed a loaded rifle and threatened to kill him. At approximately 6:00 A.M. Sergeant Shawn Kramer located Huffaker walking his dog in a nearby field. Sgt. Kramer did not activate his lights or siren and did not otherwise make contact with Huffaker. Huffaker noticed Sgt. Kramer’s vehicle and approached it. Sgt. Kramer then informed Huffaker of Savage’s allegations against him. At that time, Sgt. Kramer noticed that Huffaker appeared intoxicated. Sgt. Kramer offered to give Huffaker a ride to the Sheriff’s Office so he could give Deputy Levi Maydole his side of the story. Huffaker agreed, and Sgt. Kramer drove Huffaker and his dog to the Sheriff’s Office. During the ride to the Sheriff’s Office, Huffaker rode in the passenger seat of Sgt. Kramer’s law enforcement vehicle while his dog rode in the back seat. In the course of his interaction with Sgt. Kramer, Huffaker was not frisked or handcuffed. He was not physically or verbally coerced by Sgt. Kramer into entering the law enforcement vehicle. He was never told that he was being arrested, detained, or otherwise deprived of his freedom. After a roughly five minute interview, Deputy Maydole informed Huffaker that he was under arrest. Roughly three hours after having been arrested, Huffaker requested and was provided with a “Voluntary Statement” form, on which he wrote down an account of the events from that morning, which contained incriminating statements similar to those he had made during his interview with Deputy Maydole. Prior to trial, the district court suppressed both Huffaker’s interview and his written statement under Miranda. The district court reasoned that Huffaker was “in custody” during the interview because: (1) “Defendant has no way of returning home because he was intoxicated and Kramer had given him a ride to the station”; (2) “Defendant was questioned as the sole suspect by a law enforcement officer”; (3) “[h]e was not told he was free to leave”; and (4) “[a] normal person in Defendant’s circumstances would not have believed they could end the interview and freely leave the police station.” Following entry of the order granting Huffaker’s motion to suppress, the State appealed to the Court of Appeals. The Court of Appeals affirmed the order as to Huffaker’s written statement, but reversed as to his oral statements, concluding that he was not in custody when those statements were made. The Supreme Court vacated the district court's order suppressing both Huffaker's written and oral statements, finding that Huffaker was not in custody when his statements were made, and that the written statement was not drafted in response to interrogation.
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