Supreme Court of Florida

State of Florida, Petitioner v. Michael Lindsey McAdams, Respondent; Michael Lindsey McAdams, Petitioner, v. State…

April 21, 2016193 So. 3d 824

Summary

The court held that Florida's Due Process Clause requires law enforcement to notify a person being questioned in a nonpublic location when an attorney retained on that person's behalf arrives and is available to assist, regardless of whether the person is in custody. It also held that McAdams was in custody before confessing, so the failure to give Miranda warnings rendered the confession inadmissible, and the error was harmful. The court quashed the district court's decision and remanded. Justice Polston, concurring in part and dissenting in part, agreed that the confession should be suppressed but would not extend the attorney-notification rule to noncustodial interviews.