The body of Darla Cline was found at her place of employment, an all-night diner in the busy metropolis of Zebulon, NC. She had been beaten and stabbed to death. Also, $1,500 in change used for amusement games in the diner had been taken from its usual place (a small box kept in the kitchen).
Later that morning, our hero, Detective Duckworth, received word that patrol officers had stopped Medlin for a minor traffic violation around 4:00 a.m. of that day. During a consent search of the vehicle, officers found a bag containing over $800 in quarters. Medlin told the officers he owned a video arcade and that the money was from his business. He also said he was staying in a local motel. Officers then cited Medlin for an expired registration and sent him on his way.

Duckworth went immediately to the motel and asked Medlin to accompany him to the police station for questioning in the Cline case. He stated, "Mr. Medlin, you're not under arrest, but I'd like you to accompany me down to the police station for questioning in the Cline case." Medlin agreed. The Zebulon police station was a narrow, one-story building that had formerly housed a barbershop. A few offices and the restrooms were located in the rear, while numerous desks and a waiting area were in the front section of the building. Holding cells were in a separate structure located behind the station. All but one of the desks in the station was occupied by a uniformed officer or detective.

Duckworth and Medlin took a seat at the empty desk, and the detective asked Medlin whether he had ever met Darla Cline. Almost immediately, Medlin blurted out that he had killed Darla Cline and had taken money from the diner. Detective Duckworth then arrested Medlin, read him his Miranda rights, and continued his questioning. Medlin eventually asked Duckworth if the detective thought he needed a lawyer. Duckworth responded Medlin could get a lawyer if he wanted one, but that it would have to be his choice to do so. Duckworth replied, "I know you can't get a lawyer for me now, but I'll want one for my trial. For now, I feel better just talking to you." Medlin then gave additional incriminating statements. Medlin was allowed to use the restrooms during the questioning, though an officer was always in the restroom with him, and he was provided with a Coke when he requested it.

On the basis of his statements, Medlin was convicted of Darla Cline's murder. He now appeals on grounds that the Zebulon Police Department violated his rights under Miranda v. Arizona.

What result?
What factors might Medlin rely on to argue the police acted improperly? How might the state respond?

Submitted by Richard Wright

Wake Forest University

Answer

Compare State v. Smith (Chapter 8) with State v. Medlin, 333 N.C. 280 (1993).

(1) Generally, Miranda requires that when a suspect is interrogated while in the custody of the police he be given his Miranda rights.  Any statement obtained in violation of Miranda is considered to be inadmissible.

(2) In this case the Court held that Medlin was not in "custody"; therefore, the Miranda warning was not required and the confession was inadmissible.  The test for "custody" is objective, and the issue is whether a reasonable person in the suspects position would believe he was or was not in custody.  The suspect need not be arrested in order to be in custody.

(3) In this case the Court also held that even if Medlin was found to be in custody, he had waived his right to counsel.  Any waiver must be knowingly and intelligently made.  In this case, it was.