Searching over 5,500,000 cases.

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

State v. Ruiz

Supreme Court of Indiana

June 3, 2019

State of Indiana, Appellant (Plaintiff)
Ernesto Ruiz, Appellee (Defendant)

          Argued: February 21, 2019

          Appeal from the Jackson Circuit Court, No. 36C01-1510-F4-25 The Honorable Richard W. Poynter, Judge

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

          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



         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 ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.