Recently, a state appellate court issued an opinion in a New York Leaving the Scene of an Accident case which required the court to analyze whether a defendant’s statements that were elicited before he was given his Miranda warnings were admissible at trial. Ultimately, the court held that, because the defendant was not in custody when he made the statements, the detective interviewing him did not need to Mirandize the defendant. Thus, the statements were admissible and the defendant’s conviction was affirmed.
The Facts of the Case
According to the facts contained in the appellate opinion, a pedestrian was struck by a pickup truck in East Islip. Throughout the course of the investigation, the detective got a lead that the defendant had a pickup truck that matched the description of the one that hit the pedestrian.
The detective went to the defendant’s home. When the detective arrived, he told the defendant why he was there, and the defendant voluntarily answered a few preliminary questions. The defendant also agreed to let the detective check out his vehicle.
As the detective was circling the defendant’s truck, he noticed that one of the truck’s headlights was missing. This prompted the detective to ask the defendant where he was on the night of the accident. The defendant explained he was at a nearby bar and, upon further questioning, admitted that his route home took him along the road where the pedestrian was hit.
At this point, the detective asked to search the defendant’s home. The detective then read the defendant his Miranda warnings. Eventually, the detective arrested the defendant for leaving the scene of an accident and related charges.
In a pretrial motion to suppress, the defendant argued that his statements about his whereabouts on the night of the accident should not be admissible at trial, because they were taken in violation of his constitutional rights. Specifically, the defendant claimed that the detective should have read him his Miranda warnings before questioning him.
However, the court disagreed, finding that the detective was under no duty to read the defendant his Miranda rights because he was not in custody at the time of the questioning. The court explained that Miranda only protects against custodial interrogations, which requires the defendant either to be physically in custody or reasonably believe that he is not free to leave. Here, the court explained that the defendant was at his own home, talking to the detective voluntarily, and was not physically restrained at any time. Thus, the court determined that the defendant was not in custody, and the detective did not need to provide him with his Miranda rights before questioning him.
Have You Been Arrested for a New York Crime?
if you have recently been arrested after making a statement to detectives, there may be a basis to keep that statement out of evidence. At the criminal defense law firm of Tilem & Associates, we represent clients facing all types of serious allegations, including New York traffic crimes, sex offenses, weapons charges, and more. We aggressively defend our clients from the moment we begin working on their case, and do everything we can to help them move past their arrest so they can get on with their life. To learn more, and to schedule a free consultation with an attorney today, call 877-377-8666, or fill out our online form and one of our attorneys will reach out to you shortly.