State of Arkansas Appellant v. Mark E. Payton Appellee

Summary

The court dismissed the State's interlocutory appeal because the challenged suppression ruling required applying Miranda to the particular facts of Payton's interview, presenting a mixed question of law and fact rather than an issue warranting a State appeal under Rule 3. The court therefore did not decide whether Payton was in custody or whether Miranda warnings were required. Justice Wood, joined by Justice Goodson, dissented, reasoning that the appeal presented a pure legal question concerning whether custody is required before Miranda protections apply and should have been reversed and remanded.