State v. LoweAnnotate this Case
Defendant, who was eighteen years old at the time, was badly injured in a single-vehicle accident. While she lay sedated at the hospital, a police trooper, without providing Miranda warnings, questioned Defendant about the car accident, seeking information as to who was driving. After a pause in the questioning, the trooper told Defendant that two of her friends who had been in the car were dead and urged Defendant to tell the truth about who was driving. Defendant subsequently made inculpatory statements. Defendant was indicted on two counts of manslaughter, two counts of aggravated criminal OUI, and one count of leaving the scene of an accident that resulted in serious bodily injury. The trial court granted Defendant's motion to suppress as to all statements Defendant made after the pause in the interview, concluding (1) at that point, Defendant became a suspect and was in custody because she reasonably did not believe that she was free to terminate the interview; and (2) consequently, Defendant should have been given Miranda warnings. The Supreme Court affirmed, holding that the district court did not err in finding that Defendant's statements throughout were voluntary but that Defendant was in custody after the break in the interview.