Aaron L. Fansler Appellant (defendant Below) v. State of Indiana Appellee (plaintiff Below).

Summary

The Indiana Supreme Court held that Indiana Evidence Rule 617 did not require electronic recording of Fansler’s post-Miranda statements because the motel room where officers questioned him was not a place of detention. The room was privately owned, used by police only sporadically, and primarily used for surveillance and executing the arrest rather than routine custodial interrogations. The court therefore affirmed the conviction and did not reach harmless error or the booking exception.