State v. Garrison

Summary

The court held that the defendant was not in Miranda custody while questioned by police in his hospital room because the totality of the circumstances did not amount to a restraint comparable 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 had voluntarily gone to the hospital and remained alert and communicative. The court therefore reversed the Appellate Court and directed it to affirm the trial court’s judgment. Justice McDonald, joined by Justice Ecker, dissented and would have affirmed the determination that the statements were obtained during custodial interrogation and that their admission was not harmless.