- Miranda Warnings Required for Brief Detention
- April 26, 2012 | Author: G. Ross Trindle
- Law Firm: Best Best & Krieger LLP - Los Angeles Office
Overview: A California appeals court has ruled that, without Miranda warnings, the incriminating evidence obtained after a suspect was handcuffed and placed in a police vehicle was inadmissible. The court found that a “reasonable person” under these circumstances would have felt restraint comparable to a formal arrest so that the statements he made while “in custody” required Miranda warnings. Without the warnings, the suspect’s incriminating statements had to be suppressed.
Police Chief Training Point: This case illustrates the importance of understanding what factors can transform an investigatory stop into a detention requiring Miranda warnings. A critical question to ask from an objective perspective is: “Does the subject feel free to leave?” If yes, then no warnings are required. Otherwise, a failure to provide warnings is likely to lead to the suppression of important evidence. Brevity of the stop is not the sole or determinative factor. However, handcuffing a suspect and placing him in the back of a police car are “unmistakable indicia of arrest” that increase the “custodial pressure” on the suspect, requiring the procedural safeguards. This case does not affect the admissibility of spontaneous statements.
Summary Analysis: In People v. Bejasa, police investigating a collision found two syringes in Bejasa’s car. Bejasa admitted that he injected methamphetamine and was on parole. The officer handcuffed Bejasa, said he was being detained for a possible parole violation and placed him in his police car. When other officers arrived, Bejasa was released and made incriminating statements during a sobriety test. He was given no Miranda warnings. Bejasa claimed these statements should have been suppressed and the appellate court agreed, finding that the evidence obtained while Bejasa was “in custody” violated his Miranda rights.