Michigan v. Elliott (Opinion - Leave Granted)
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Defendant Samuel Elliott was convicted of armed robbery for holding up a gas station. He had been on parole for a prior conviction, and was arrested the day after the alleged robbery for a parole violation. Defendant's brother called police to inform them of Defendant's misdeed. Police interrogated Defendant until he invoked his right to counsel. While in jail, Defendant confessed his crime to a parole officer when she asked about the gas station robbery and the ramifications of having violated parole. The parole officer did not inform Defendant of his Miranda rights before questioning him. Defendant unsuccessfully moved to suppress his statements made to the parole officer at trial. The appellate court reversed, finding the statements should have been suppressed. After review, the Supreme Court concluded that the trial court did not err in its conclusion that because Defendant was not subject to a custodial interrogation by the parole officer, even if she was a law enforcement officer, neither Defendant's right to be given a series of warnings before custodial interrogation nor his right to have counsel present during custodial interrogation was violated.
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