The Indiana Court of Appeals affirmed the denial of a woman’s motion to suppress evidence admitted related to her driving while intoxicated charges.
In February 2017, Ashley Reid was charged with operating a vehicle while intoxicated endangering a person and operating a vehicle with an alcohol concentration equivalent of 0.15 or more, both Class A misdemeanors.
Reid moved to suppress all oral and written communications, confessions, statements, or admissions alleged to have been made by her, as well as any test results arising from the July 29, 2016 incident in which she interacted with a Columbus police officer.
Body camera footage was admitted from responding Officer James Paris when he arrived at the scene of a home where two women were standing in a driveway next to a damaged vehicle, which belonged to Reid. After questioning her about damage to the front of her vehicle and her apparent intoxication, Paris handcuffed Reid and transported her to Columbus Regional Hospital.
Reid was ultimately denied her motion to suppress by the trial court. On appeal, she argued it erred in that denial, contending that Paris detained her and conducted a custodial interrogation of her at her residence without first advising her of her Miranda rights.
Among other things, Reid argued that she was detained without reasonable suspicion supported by articulable facts that criminal activity could be afoot and that her statements did not clearly establish the time when she had been the driver of the vehicle.
She further argued that she was not free to leave her encounter with Paris and no reasonable person would have believed she was permitted to leave, as he “immediately began interrogating [her] upon his arrival,” and that the conversation was not consensual.
However, the appellate court found that under the circumstances, Reid’s Fourth and Fifth Amendment rights were not violated because the facts and reasonable inferences pointed otherwise.
“Based on our review of the record and the totality of the circumstances, and in light of the nature of the questioning and the relative degree of police control over the environment in which it was conducted, we cannot say that there had been a formal arrest or restraint on Reid’s freedom of movement of the degree associated with a formal arrest at the time she made her statements,” Judge Elaine Brown wrote for the court.
“The degree of concern, suspicion, or knowledge that a violation had occurred was high,” she continued. “We also observe that the degree of intrusion here was minimal: in responding to a call to dispatch from Reid’s husband, Officer Paris approached a driveway to encounter a vehicle with damage to the rear passenger-side bumper and a flat front passenger-side tire which had its rubber ‘shredded around the wheel’ … and to ask questions of Reid, who identified herself and answered affirmatively when asked ‘is this your vehicle’ and ‘did you just get home.’”
Therefore, the appellate court concluded that Reid’s Miranda rights were not violated and further affirmed the denial of her motion to suppress in Ashley Reid v. State of Indiana, 18A-CR-493.