State v. GueinAnnotate this Case
The Supreme Court affirmed in part and reversed in part the decision of a majority of the court of appeals panel reversing in part and affirming in part the district court's decision on Defendant's motion to suppress evidence, holding that neither Defendant's pre-Miranda statement nor his post-Miranda statement were admissible in evidence.
The district court found admissible Defendant's pre-Miranda statement that he had marijuana on his person but suppressed Defendant's pre-Miranda statement that he had marijuana in his car. The district court also ruled that Defendant's post-Miranda statements were admissible because at that point Defendant had voluntarily waived his rights. The court then ruled that Defendant's pre-Miranda statement about the marijuana on his person was admissible and that the doctrines of plain view and inevitable discovery applied to the evidence in Defendant's car. The court of appeals set aside Defendant's convictions and ordered a new trial, holding that the district court erred in denying Defendant's motion to suppress his post-Miranda statement as coerced. The Supreme Court reversed in part, holding (1) the pre-Miranda statement Defendant made surrounding his initial pat-down was not admissible as evidence because he was being interrogated in custody at the time; and (2) Defendant's post-Miranda statement was inadmissible due to implied physical violence toward Defendant.