State v. Mattheisen

Under Article I, section 12 of the Oregon Constitution, officers must give a suspect Miranda warnings when questioning occurs under compelling circumstances. Courts look to four factors to determine whether a situation is compelling: (1) the location of the encounter; (2) the length of the encounter, (3) the amount of pressure exerted on the defendant; and (4) the defendant’s ability to terminate the encounter.

Defendant appealed a judgment convicting him of first-degree sexual abuse, assigning error to the trial court’s denial of Mattheisen’s motion to suppress evidence of his incriminating statements made to officers without prior Miranda warnings. Defendant argued the questioning and statements occurred under “compelling” circumstances, and that by not giving Mattheisen Miranda warnings the officers violated his Article I, section 12 rights under the Oregon Constitution. In determining whether circumstances are compelling and require Miranda warnings under the Oregon Constitution, courts look to four factors: “(1) the location of the encounter; (2) the length of the encounter, (3) the amount of pressure exerted on the defendant; and (4) the defendant’s ability to terminate the encounter.” The ultimate inquiries to determine whether questioning occurred under compelling circumstances are whether the officers created a “police-dominated atmosphere” using evidence of guilt in a coercive manner against a suspect, and how a reasonable person in the suspect’s position would have understood the situation. The Court found that while the fourth factor favored the state, the first three factors created a compelling situation. The third factor most strongly indicated compelling circumstances, as the officers’ repeated and coercive statements–predicated on an inherent assumption of Mattheisen’s guilt–were designed to rebut Mattheisen’s repeated statements of innocence. The totality of the circumstances creating a compelling situation in which Mattheisen should have received Miranda warnings. Reversed and remanded.