State v. Vasconcellos
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The Supreme Court vacated in part the judgment of the intermediate court of appeals (ICA) affirming the district court's order granting Defendant's motion to suppress statements after finding that Defendant was subject to custodial interrogation without being given Miranda warnings, holding that the ICA erred in affirming the district court's suppression of Defendant's responses to medical rule-out questions.
Defendant was arrested and charged with operating a vehicle under the influence of an intoxicant and reckless driving. Defendant moved to suppress his answers to the medical rule-out questions, asserting that he was subject to custodial interrogation without being given Miranda warnings. The ICA affirmed. The Supreme Court vacated the judgment in part, holding (1) because the circumstances of Defendant's stop did not rise to that of a formal arrest Defendant was not in custody at the time he was asked the medical rule-out questions; and (2) therefore, Miranda warnings were not required.
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