State v. BrownAnnotate this Case
Defendant entered a field sobriety checkpoint and was asked if he had been drinking. Defendant admitted that he had. The officer administered some field sobriety tests and ultimately arrested Defendant. Defendant was charged with operating while intoxicated and operating a vehicle with an alcohol concentration of at least .08 but less than .15 grams of alcohol per 210 liters of breath. During trial, Defendant’s counsel objected to the officer’s testimony about him asking Defendant if he had been drinking and Defendant’s response based on a Miranda violation. In response, the State argued that a Miranda warning was not necessary. The trial court then entered an order suppressing any statements made by Defendant, as well as any evidence obtained thereafter. On appeal, the Court of Appeals, dismissed the appeal, ruling that the State had no statutory authority to appeal because Defendant never filed a written motion to suppress and because the order suppressing the evidence was issued during trial. The Supreme Court granted transfer and reversed the trial court’s suppression order, holding (1) the State may appeal from the trial court’s order granting Defendant’s motion to suppress; and (2) Miranda warnings are not required in circumstances such as these, where a defendant is briefly detained at a public sobriety checkpoint.