State v. Garrison

Summary

The court held that the defendant was not in Miranda custody during police questioning in his hospital room because the totality of the circumstances did not show restraint equivalent to a formal arrest. The officers did not physically restrain him, control his medical care, use aggressive questioning, or prevent him from ending the interviews, and he voluntarily went to the hospital and remained able to communicate and move about. The court therefore reversed the intermediate appellate judgment and remanded for consideration of the defendant's remaining claims. McDonald, J., joined by Ecker, J., dissenting, would have affirmed because the cumulative circumstances showed custody and the admission of the statements was not harmless beyond a reasonable doubt.