State v. Troutman

Summary

The court held that Troutman was in custody before his third police interview because he had been isolated for hours, repeatedly questioned, told he could not leave, and never advised of his rights or freedom to depart. His unwarned inculpatory statement was therefore properly suppressed under Miranda. The court nevertheless held that the statement was voluntary under due process standards because the investigators’ conduct, though sufficient to establish custody, did not constitute coercive police activity.