State v. Mast
301 Or.App. 809 (2020)
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Rule of Law:
When police obtain an unwarned confession under compelling circumstances, belatedly administered Miranda warnings are ineffective if the interrogation is a single, continuous event. Consequently, both the subsequent warned statements and any physical evidence derived from the initial violation must be suppressed.
Facts:
- Around 1:40 a.m., Deputy VanDrimmelen found a crashed and abandoned pickup truck belonging to Henry Lloyd Mast.
- The truck was locked with valuable items inside, and no keys were visible.
- A sheriff's dispatcher later informed VanDrimmelen that Mast had called to report the truck as stolen.
- Mast agreed to meet police at the rural, unlit crash site, where he was transported by a friend.
- Deputy VanDrimmelen and two other uniformed, armed deputies, Schreiber and Ruble, arrived in three separate police vehicles, at least one with its overhead lights activated.
- Mast appeared intoxicated. While VanDrimmelen questioned him, the other two deputies stood behind Mast.
- VanDrimmelen told Mast he did not believe the truck was stolen and implicitly threatened him with criminal charges for filing a false report unless he was honest.
- Following this confrontation and before being read any Miranda rights, Mast admitted he had been drinking, driving, and crashed the truck.
Procedural Posture:
- The State charged Henry Lloyd Mast in Douglas County Circuit Court (trial court) with driving under the influence of intoxicants and failure to perform the duties of a driver.
- Mast filed a motion to suppress his statements and all derivative evidence, arguing they were obtained in violation of his Miranda rights.
- The trial court partially denied the motion, suppressing only Mast's initial admission that he was driving but allowing his other statements and the results of the field sobriety and breath tests.
- Following the ruling, Mast entered a conditional guilty plea, reserving his right to appeal the trial court's partial denial of his suppression motion.
- Mast (as Defendant-Appellant) appealed the judgment of conviction to the Court of Appeals of Oregon.
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Issue:
Does a violation of a suspect's Miranda rights require suppression of not only his initial unwarned statements, but also his subsequent post-warning statements and the results of sobriety tests, when the belated warnings are given mid-interrogation without a sufficient break to dissipate the taint of the initial violation?
Opinions:
Majority - Shorr, J.
Yes, the Miranda violation requires suppression of all resulting evidence. The belatedly administered Miranda warnings were ineffective to ensure a knowing and voluntary waiver of defendant’s Article I, section 12, rights, and the physical evidence derived from that violation. First, the trial court correctly identified that the interrogation occurred under compelling circumstances once VanDrimmelen used implicit threats of prosecution, requiring Miranda warnings. The failure to provide them rendered all of Mast's unwarned statements inadmissible. Second, applying the Vondehn factors, the subsequent Miranda warnings by Deputy Schreiber were ineffective because the interrogation was a single, continuous event. There was no break in time or location, the same officers were present, and Schreiber explicitly referred back to the unwarned confession, treating the second round of questioning as continuous with the first. Finally, applying the Jarnagin factors, the field sobriety and breath test results were derivative of the Miranda violation, as Mast's decision to consent was tainted by the coercive nature of the initial unwarned interrogation and the state's use of those illegally obtained admissions to seek further evidence.
Analysis:
This case reinforces and clarifies the application of Oregon's tests for belated Miranda warnings (Vondehn) and derivative evidence (Jarnagin). The court's decision emphasizes that a mere change in the questioning officer is insufficient to cure an initial Miranda violation if the interrogation maintains continuity in time, place, and subject matter. It signals that courts will scrutinize the objective circumstances to determine if a suspect could make a truly voluntary and informed choice after a prior tainted confession. This holding narrows the state's ability to salvage evidence after an initial failure to warn, making it harder to argue that mid-interrogation warnings effectively 'reset' the encounter.
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