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Friday, March 03, 2017

Ind. Decisions - Supreme Court issues 1 today

In State of Indiana v. David Brown, a 10-page, 5-0 opinion, Justice David writes:

This case involves whether the brief detainment of defendant as part of a sobriety checkpoint is custodial so as to trigger Miranda protection. We hold that such detainment is no more custodial than a routine traffic or Terry stop, and thus, defendant was not entitled to Miranda warnings at the sobriety checkpoint. * * *

We hold that the State could properly bring its appeal in this case because the trial court granted a motion to suppress and the suppression order was so broad that it effectively precluded further prosecution. We further hold that under the facts and circumstances of this case, where the sobriety checkpoint at issue was: 1) brief and temporary in duration; and 2) public, Miranda warnings were not required because Brown was not in custody. Accordingly, we reverse the trial court’s suppression order and remand for further proceedings.

Rush, C. J., Massa and Slaughter, J.J., concur.

Rucker, J., concurs in result with separate opinion.

Because I believe a motorist detained at a sobriety checkpoint is entitled to the protection afforded by Miranda v. Arizona, 384 U.S. 436 (1966), I disagree with that portion of the majority opinion declaring otherwise. However, I acknowledge the United States Supreme Court has declined to expand Miranda’s reach to cases involving routine traffic stops and its reasoning is applicable to the case before us. Therefore, I am compelled to concur in result.

Posted by Marcia Oddi on March 3, 2017 11:29 AM
Posted to Ind. Sup.Ct. Decisions