State v. Ruiz

Decision Date03 June 2019
Docket NumberSupreme Court Case No. 19S-CR-336
Parties STATE of Indiana, Appellant (Plaintiff) v. Ernesto RUIZ, Appellee (Defendant)
CourtIndiana Supreme Court

ATTORNEYS FOR APPELLANT: Curtis T. Hill, Jr., Attorney General of Indiana, Henry A. Flores, Jr., Laura R. Anderson, Tyler G. Banks, Deputy Attorneys General, Indianapolis, Indiana

ATTORNEYS FOR APPELLEE: Andrew J. Baldwin, Mark E. Kamish, Baldwin Kyle & Kamish, P.C., Franklin, Indiana

On Petition to Transfer from the Indiana Court of Appeals, No. 36A01-1712-CR-2999

Rush, Chief Justice.

If police interrogate someone in custody without providing Miranda warnings, the person's interrogated statements are generally inadmissible as evidence against that individual in a criminal trial.

Here, two police officers interrogated Ernesto Ruiz in a secured area at a police station, without providing him Miranda warnings. When the State tried to use statements Ruiz made during the interrogation as evidence against him in a criminal trial, he moved to suppress them as inadmissible. The trial court granted the motion.

The State appealed, arguing suppression was contrary to law because Ruiz—although interrogated—was not in custody. Finding substantial, probative evidence that he was in custody, we affirm the trial court's decision.

Facts and Procedural History

In a small, windowless room in a secured area of the Seymour Police Department, two police officers tag-teamed an interrogation of Ernesto Ruiz, who had been accused of a crime. Neither officer gave him Miranda warnings, and multiple times the officers told Ruiz that he was to "sit tight" in the interrogation room.

Later, the State sought to use a video of the interrogation as evidence against Ruiz in a criminal trial. Ruiz moved to suppress it, arguing his statements in the video were inadmissible because they were made during custodial interrogation in the absence of Miranda warnings.

The trial court heard evidence on the matter: testimony from the two officers who interrogated Ruiz, and the audio–video recording of the interrogation. The court also heard arguments, which the court considered overnight along with relevant caselaw. The next day, the court heard more testimony and argument, and then granted Ruiz's motion to suppress.

In granting the motion, the court recognized—rightly—that whether Ruiz was in custody turns on objective circumstances.1 It then determined that the environment was "a police setting" in which multiple officers questioned Ruiz in an accusatory and focused way in a room behind several closed doors. The court observed that although Ruiz went to the police station on his own, he "had to be buzzed into the area or taken into the area of a secure room." And although the first officer told Ruiz he could walk out of the interrogation-room door, the court found that statement, in this specific context, would not make a reasonable person feel free to leave. The court emphasized that after the second officer later entered the room, shut the door, and took on the role of interrogator, Ruiz was not told that he could leave or that the first officer's initial statement remained valid.

The State claimed that it could not proceed without the evidence that had been suppressed. For this reason, and since a jury had already been empaneled, the court declared a mistrial.

The State appealed the suppression decision, see Ind. Code § 35-38-4-2(5) (2018), and a panel of the Court of Appeals reversed, concluding the interrogation was not custodial, State v. Ruiz , No. 36A01-1712-CR-2999, 2018 WL 3543561, at *5 (Ind. Ct. App. July 24, 2018).

Ruiz petitioned for transfer, which we now grant, vacating the Court of Appeals decision. Ind. Appellate Rule 58(A).

Standard of Review

The State brings this appeal under Indiana Code 35-38-4-2(5), which authorizes the State to appeal an order granting a motion to suppress if the order ultimately prevents further prosecution of at least one charged count. This kind of appeal, we have recognized, is one from a negative judgment. See, e.g. , State v. Brown , 70 N.E.3d 331, 334–35 (Ind. 2017) ; State v. Keck , 4 N.E.3d 1180, 1183 (Ind. 2014) ; State v. Washington , 898 N.E.2d 1200, 1202–03 (Ind. 2008) ; see also State v. Estep , 753 N.E.2d 22, 24–25, 24 n.5 (Ind. Ct. App. 2001) ; State v. Ashley , 661 N.E.2d 1208, 1211 (Ind. Ct. App. 1995). A negative judgment is the denial of relief to a party on a claim for which that party had the burden of proof. See Ben-Yisrayl v. State , 738 N.E.2d 253, 258 (Ind. 2000).

It is true that Ruiz filed the motion to suppress his statements. But no matter Ruiz's burden to support his challenge to the statements' admission,2 the trial court, in granting his motion, necessarily determined that the State failed to carry its countervailing burden to prove that the statements were admissible. See Colorado v. Connelly , 479 U.S. 157, 167–69, 107 S.Ct. 515, 93 L.Ed.2d 473 (1986) ; Lego v. Twomey , 404 U.S. 477, 488–89, 92 S.Ct. 619, 30 L.Ed.2d 618 (1972). Specifically, since Ruiz brings his challenge under the Federal Constitution, the State had to show by a preponderance of the evidence that Ruiz voluntarily waived his Miranda -protected rights before he made the statements. See United States v. Charles , 738 F.2d 686, 696 (5th Cir. 1984), abrogated on other grounds by United States v. Bengivenga , 845 F.2d 593, 596–97 (5th Cir. 1988) (en banc); United States v. Miller , 382 F. Supp. 2d 350, 362 (N.D.N.Y. 2005) ; Smith v. State , 689 N.E.2d 1238, 1246 & n.11 (Ind. 1997). The State also bore the ultimate burden at trial to prove guilt beyond a reasonable doubt. See Taylor v. State , 587 N.E.2d 1293, 1301 (Ind. 1992).

So, since the suppression order rested on the State's failure to carry its burden to prove the statements' admissibility, and that decision precludes the State from further prosecuting a criminal charge, which the State had the burden to prove, the State appeals from a negative judgment. Accordingly, the State must show that the trial court's decision was contrary to law—meaning that the evidence was without conflict and all reasonable inferences led to a conclusion opposite that of the trial court. See Brown , 70 N.E.3d at 335 ; State v. McCaa , 963 N.E.2d 24, 29 (Ind. Ct. App. 2012), trans. denied . The State cannot make this showing if there is substantial, probative evidence supporting the suppression ruling. See Brown , 70 N.E.3d at 335.

Here, the trial court's suppression decision was proper if Ruiz was under custodial interrogation, which triggers Miranda . Because the State admits that Ruiz was under interrogation, we focus our review on the trial court's determination that Ruiz was in custody.

The custody inquiry is a mixed question of fact and law: the circumstances surrounding Ruiz's interrogation are matters of fact, and whether those facts add up to Miranda custody is a question of law. See Thompson v. Keohane , 516 U.S. 99, 112–13, 116 S.Ct. 457, 133 L.Ed.2d 383 (1995). We defer to the trial court's factual findings, without reweighing the evidence; and we consider conflicting evidence most favorably to the suppression ruling. State v. Quirk , 842 N.E.2d 334, 340 (Ind. 2006). But we review de novo the legal question of whether the facts amounted to custody. Brown , 70 N.E.3d at 335.

Discussion and Decision

Under Miranda v. Arizona , if Ruiz was under "custodial interrogation," the police were required to give him certain warnings about his rights, and the absence of those warnings precludes the use of his statements to prove guilt. 384 U.S. 436, 444, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966).

The State acknowledges that Ruiz was under police interrogation but contends that he was not in custody. Custody under Miranda occurs when two criteria are met. First, the person's freedom of movement is curtailed to "the degree associated with a formal arrest." Maryland v. Shatzer , 559 U.S. 98, 112, 130 S.Ct. 1213, 175 L.Ed.2d 1045 (2010) (quoting New York v. Quarles , 467 U.S. 649, 655, 104 S.Ct. 2626, 81 L.Ed.2d 550 (1984) ). And second, the person undergoes "the same inherently coercive pressures as the type of station house questioning at issue in Miranda ." Howes v. Fields , 565 U.S. 499, 509, 132 S.Ct. 1181, 182 L.Ed.2d 17 (2012).

We hold that the State did not carry its burden here to show that the trial court's ruling was contrary to law. The record includes substantial, probative evidence of circumstances that, taken altogether, met both criteria of Miranda custody. We'll address each in turn.

I. The totality of objective circumstances surrounding the interrogation would make a reasonable person feel not free to end the questioning and leave.

Under Miranda , freedom of movement is curtailed when a reasonable person would feel not free to terminate the interrogation and leave. Howes , 565 U.S. at 509, 132 S.Ct. 1181. This freedom-of-movement inquiry requires a court to examine the totality of objective circumstances surrounding the interrogation—such as the location, duration, and character of the questioning; statements made during the questioning; the number of law-enforcement officers present; the extent of police control over the environment; the degree of physical restraint; and how the interview begins and ends. See id. ; Oregon v. Mathiason , 429 U.S. 492, 493, 97 S.Ct. 711, 50 L.Ed.2d 714 (1977) (per curiam); United States v. Infante , 701 F.3d 386, 396 (1st Cir. 2012) ; Sprosty v. Buchler , 79 F.3d 635, 641 (7th Cir. 1996).

Here, the State argues that Ruiz's freedom of movement was not curtailed and thus he was not in custody. The State points to certain evidence in support: Ruiz provided his own transportation to the police station; the first interrogating officer told him, "you don't have to talk to me" and "you can get up and walk out that door at any time"; Ruiz sat near the unlocked interview-room door and had not been arrested; the interrogation lasted less than an hour; and Ruiz left unhindered...

To continue reading

Request your trial
18 cases
  • Hayko v. State
    • United States
    • Court of Appeals of Indiana
    • 28 Septiembre 2022
    ...house questioning at issue in Miranda ." Howes v. Fields , 565 U.S. 499, 509, 132 S. Ct. 1181, 182 L. Ed. 2d 17 (2012). State v. E.R. , 123 N.E.3d 675, 680 (Ind. 2019).14] Here, the court admitted Hayko's statement in evidence. And the record contains facts supporting the court's decision t......
  • Wahl v. State
    • United States
    • Court of Appeals of Indiana
    • 12 Mayo 2020
    ...rights. [38] The question of whether a person is in custody for purposes of Miranda is a mixed question of fact and law. State v. Ruiz , 123 N.E.3d 675, 679 (Ind. 2019). The test for whether a defendant is in custody is not whether a defendant feels free to go, but rather whether there was ......
  • Crabtree v. State
    • United States
    • Court of Appeals of Indiana
    • 2 Septiembre 2020
    ...certain warnings about his rights, and the absence of those warnings precludes the use of his statements to prove guilt." State v. Ruiz , 123 N.E.3d 675, 679-80 (Ind. 2019) (citation omitted), cert. denied . Accordingly, we will consider whether Crabtree was in custody at the time of the in......
  • State v. O.E.W., Court of Appeals Case No. 18A-JV-2409
    • United States
    • Court of Appeals of Indiana
    • 19 Agosto 2019
    ...[24] The question of whether a person is in custody for purposes of Miranda is a mixed question of fact and law. State v. Ruiz , 123 N.E.3d 675, 679 (Ind. 2019). The circumstances surrounding the interrogation are questions of fact, and whether those facts add up to custody for Miranda purp......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT