Michigan Supreme Court Remands on Miranda Issue

Case: People v. Barritt

Court: Michigan Supreme Court ( Order )

Judges: Markman, Zahra, McCormack, Viviano, Bernstein, Larsen, and Wilder

Issues:

Motion to suppress statements made during a police interview; Whether the defendant was subject to custodial interrogation; Miranda v. Arizona; Howes v. Fields; Yarborough v. Alvarado; People v. Elliott

Summary:

In an order in lieu of granting leave to appeal, the court vacated the part of the Court of Appeals’ judgment (see e-Journal # 64573 in the 2/16/17 edition for the published opinion) that ruled defendant was subjected to a custodial interrogation. The court held that while the Court of Appeals properly found that the trial court erred in “failing to apply the correct legal standards, the Court of Appeals should have remanded this case to the trial court for application of those standards in the first instance.” Thus, the court remanded the case to the trial court to determine, considering “all of the objective circumstances surrounding the interrogation: (1) whether a reasonable person would have felt that he was not at liberty to terminate the interrogation and leave; and (2) whether the environment presented the same inherently coercive pressures as the type of station house questioning at issue in” Miranda.