STATE OF FLORIDA, APPELLANT,
v.
MARK A. DUNGAN CARPENTER, APPELLEE
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The State appeals a trial court's suppression of the defendant's statements made during police interrogation. The trial court found the defendant was in custody without receiving Miranda warnings, but applied a subjective rather than objective standard in making this determination. The appellate court reverses and remands, directing application of the correct objective reasonable-person standard.
The trial court applied an incorrect legal standard by using a subjective analysis instead of the required objective, reasonable-person framework. The proper standard requires examining the circumstances surrounding the interrogation and asking whether a reasonable person would have felt free to terminate the interrogation and leave. The case is reversed and remanded for application of the correct objective standard.
[1] The determination of whether a suspect is in custody for Miranda purposes is based on an objective, reasonable-person framework.
[2] Custody for Miranda purposes is determined by considering the circumstances surrounding the interrogation and whether a reasonable person would feel free to terminate the…
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Join FLexlaw to unlock all legal intelligence“The ultimate inquiry is twofold: (1) the 'circumstances surrounding the interrogation'; and (2) 'given those circumstances, would a reasonable person have felt he or she was not at liberty to terminate the interrogation and leave.'”
Establishes the two-part objective standard that courts must apply in determining custody for Miranda purposes
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceMark A. Dungan Carpenter was interviewed by members of the Sarasota County Sheriff's Office. The trial court found that law enforcement had Carpenter …
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The State appeals the trial court’s order suppressing the statements made by Mark A. Dungan Carpenter during an interview with members of the Sarasota County Sheriffs Office. The court ruled that law enforcement had Mr. Carpenter in custody and had failed to give him his Miranda1 warnings before eliciting his incriminating statements. Because we conclude that the trial court applied the incorrect legal standard, we reverse.
A person cannot be compelled to be a witness against himself, so the constitutional protections afforded by Amendment V to the United States Constitution and by article I, section 9 of the Florida Constitution are “fully applicable during a period of custodial interrogation.” Ramirez v. State, 739 So.2d 568, 572 (Fla.1999). To determine whether these protections apply, the supreme court has “adopted an objective, reasonable-person framework in determining whether a suspect was in custody” while he was being interrogated. Peterson v. State, 94 So.3d 514, 2012 WL 1722581 (Fla.2012) (citing Ross v. State, 45 So.3d 403, 415 (Fla.2010), cert. denied,, — U.S. —, 131 S.Ct. 925, 178 L.Ed.2d 803 (2011)). “The ultimate inquiry is twofold: (1) the ‘circumstances surrounding the interrogation’; and (2) ‘given those circumstances, would a reasonable person have felt he or she was not at liberty to terminate the interrogation and leave.'” Id. (quoting Yarborough v. Alvarado, 541 U.S. 652, 663, 124 S.Ct. 2140, 158 L.Ed.2d 938 (2004)) (emphasis added).
But in this case, the trial court did not use a reasonable person standard. It erroneously concluded in its written order that “[t]his analysis is subjective[,] not objective.” The court compounded the error by concluding that “in the mind of the Defendant, he was not free to leave.” The trial court should have applied an objective standard.2
Accordingly, we reverse the trial court’s order of suppression and remand for further consideration utilizing the objective, reasonable person standard. Additionally, the trial court is directed to consider and rule upon Mr. Carpenter’s pending suppression claims so that should there be a subsequent appeal by either party, the issues may be considered at one time and not in a piecemeal manner.
Reversed and remanded with instructions.
SILBERMAN, C.J., and KELLY, J., Concur.
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Authorities Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966)
- Ramirez v. State, 739 So. 2d 568 (Fla. 1999)
- Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004)
- Blaine Ross v. State, 45 So. 3d 403 (Fla. 2010)
- Peterson v. State, 94 So. 3d 514 (Fla. 2012)