State v. Harryman

The questioning of a suspect by the police does not inherently create a compelling circumstance that requires Miranda warnings. The trial court is not required to allow modified jury instructions when the substance of the modified instruction is not necessary or the substance is covered fully by other instructions.

Defendant appeals the trial court’s denial of his motion to suppress statements made while being treated for injuries in an ambulance and appeals the trial court’s failure to give modified self-defense jury instructions. The suppression of a defendant’s statements require sufficiently compelling circumstances that call for the administration of Miranda warnings. Defendant contends that compelling circumstances existed because he was strapped to a spine immobilizing board after sustaining multiple blows to his head in a physical altercation and was not free to leave while in close proximity to an armed police officer. The Court disagreed because the questioning of a suspect by the police does not inherently create a compelling circumstance. Also, the officer did not use any aggressive or coercive police interrogations practices. The trial court’s failure to give modified legal instructions contained no legal error. Defendant contends the trial court was required to give his proposed jury instruction on self-defense. If the substance of the requested jury instruction is not necessary or covered fully by other instructions then the trial court did not error in refusing to give the modified instructions. The jury instructions given by the trial court correctly described the principles of self-defense and because certain aspects of Defendant’s requested instructions could have confused the jury the trial court did not err in denying defendant’s requested instructions. Affirmed.