Fansler v. StateAnnotate this Case
The trial court did not err in admitting Defendant’s incriminating statements made in a motel room during the course of a custodial interrogation without an electronic recording of those statements.
Defendant was charged with and convicted of several drug crimes. On appeal, Defendant argued that two post-Miranda self-incriminating statements he made to officers in a motel room should not have been admitted into evidence because no electronic recording of the statements was made available at trial, as required by Ind. R. Evid. 617. The Supreme Court disagreed, holding that a motel room, as used by law enforcement in this case to carry out an undercover investigation and to search a suspect incident to his arrest, is not a place of detention as defined by Rule 617.