People v. Carroll

PRESIDING JUSTICE HOMER

delivered the opinion of the court:

The sole issue presented by this appeal is whether defendant, Harold Carroll, was in custody, and therefore entitled to Miranda warnings, at the time he gave a taped confession. The State appeals from the trial court’s order granting defendant’s motion to suppress the confession. For the reasons that follow, we affirm. In so doing, we hold: (1) the proper test for determining whether an accused is in custody for purposes of Miranda is objective, i.e., whether a reasonable person in the accused’s position would consider himself to be in…