Earlier this year, a state appellate court issued an opinion in a New York hit-and-run case, discussing the defendant’s claim that his statement was taken in violation of his constitutional rights. However, the court rejected the defendant’s issue on appeal, noting that the requirements of Miranda were not implicated because the defendant was not in “custody” when detectives questioned him.
The Facts of the Case
According to the court’s opinion, a dark-colored pick-up truck hit a pedestrian and then fled the scene. The detective learned that the defendant had a vehicle matching the description, and went to the defendant’s home to speak with him. The detective explained that he was investigating an accident, and that the defendant’s vehicle matched the description of the one that struck the pedestrian. The defendant allowed the detective to inspect his vehicle, at which point the detective noticed that one of the truck’s headlight assemblies was missing.
The detective then asked the defendant a few follow-up questions, including where he was on the night of the incident. The defendant explained that he was at a bar, and drove home on the road where the pedestrian was hit. The detective then asked to take a look inside the defendant’s home, and read the defendant his Miranda warnings. Ultimately, the defendant was charged with leaving the scene of an accident.
In a pre-trial motion to suppress, the defendant sought suppression of his pre-Miranda statements. Namely, that he had been at a bar earlier that evening, and that his route home would have taken him on the road where the pedestrian was hit. The defendant argued that the detective should have read him his Miranda warnings before engaging in that particular line of questioning.
The court, however, disagreed, rejecting the defendant’s argument and denying his motion. The court explained that an officer is only required to read a suspect their Miranda warnings when they are subject to custodial interrogation. The standard courts use to determine if a suspect is in custody is whether a reasonable person in the defendant’s shoes would have felt free to leave in the face of the questioning.
Here, the court determined that the defendant was not “in custody” for the purposes of Miranda. The court noted that the defendant was not handcuffed and his freedom of movement was not restricted. The court also pointed out that the questioning took place at the defendant’s home, which was not a “coercive environment.” Thus, because the defendant was not in custody when the defendant questioned him, there was no requirement the detective read him his Miranda warnings.
Have You Been Arrested after Making a Statement to Police?
If you have been arrested and charged with a crime after making a statement to the police, do not assume the worst. You still have options. At the Law Offices of Mark A. Siesel, our New York criminal defense attorneys provide dedicated, aggressive representation to clients facing all types of criminal allegations, including New York vehicle crimes, weapons offenses, drug charges, and more. We have extensive experience litigating pretrial motions to suppress, and developing compelling defenses, even in the toughest of cases. To learn more, and to schedule a free consultation, call 914-224-3086 today. You can also reach out to us through our online form.