State v. KittredgeAnnotate this Case
Defendant’s probation officer asked Defendant to come to the probation office. When Defendant complied, he met two state troopers who sat down with him and asked him about a theft at the victim’s apartment. After the interview, Defendant made incriminating statements. Defendant was charged with burglary and theft by unauthorized taking or transfer. Defendant moved to suppress the statements he made to law enforcement. The trial court determined that Defendant spoke voluntarily and that he was not in custody, and therefore, Miranda warnings were not required. Defendant was subsequently convicted of theft by unauthorized taking or transfer. The Supreme Court affirmed, holding (1) the trial court did not err in determining that Miranda warnings were unnecessary because Defendant was not in custody; (2) the trial court did not err in concluding that the confession was voluntary; and (3) the evidence was sufficient to support the conviction.