State v. Shelby

Miranda warnings are required before questioning when police question a defendant under circumstances that Miranda warnings were intended to counteract.

Defendant appealed the conviction by the trial court for assault in the fourth degree. Defendant assigned error to the trial court’s decision to admit inculpatory statements made by defendant during his disciplinary hearings at the jail. Defendant argued that he was in a compelling situation and was not read new Miranda warnings when the statements were made, and thus they should be inadmissible. Miranda warnings are required before questioning when police question a defendant under circumstances that Miranda warnings were intended to counteract. The Court held that defendant was in a compelling situation and thus the statements should not have been admissible. The Court applied the totality of circumstances test and reasoned that because defendant was unaware that his presence at the disciplinary hearing was not required and that he may be facing additional criminal charges, the defendant was in a compelling situation. Nonetheless, the Court held that the error was harmless. Affirmed.