Alaska Supreme Court
Byron M. Kalmakoff, Petitioner v. State of Alaska, Respondent
June 1, 20102010 Alas. LEXIS 57
Summary
The court remanded for additional factual findings needed to determine whether the defendant was in custody at the beginning of his first interview and whether statements from that interview were obtained in violation of Miranda. Those findings were also necessary to assess whether later statements were sufficiently insulated from earlier violations to avoid suppression. The court retained jurisdiction pending the trial court's findings.