State of Arkansas Appellant v. Mark E. Payton Appellee

Summary

The Supreme Court of Arkansas dismissed the State’s interlocutory appeal from an order suppressing Mark Payton’s statement because deciding whether Miranda applied to his interview required applying the law to case-specific facts, a mixed question that did not satisfy the limited requirements for a State appeal. The court therefore did not reach whether Payton was in custody or whether the circuit court correctly suppressed the statement. Justice Wood, joined by Justice Goodson, dissented, reasoning that the State presented a pure legal question about whether custody is required before Miranda protections apply and that the appeal should have been accepted and remanded.