State v. Garrison

Summary

The court held that the defendant was not in custody for Miranda purposes during police questioning in his hospital room because the totality of the circumstances would not have led a reasonable person to perceive a restraint equivalent to formal arrest. The officers did not physically restrain him, control his medical treatment, use aggressive questioning, or prevent him from ending the interviews, and the defendant voluntarily went to the hospital. The court therefore reversed the intermediate appellate judgment and directed affirmance of the conviction. McDonald, J., joined by Ecker, J., dissenting, would have affirmed the determination that the hospital questioning was custodial and that admission of the statements was not harmless.