State v. Edenfield

VILLANTI, Judge.

The State appeals the trial court’s order suppressing statements made by Michael Byron Edenfield to a deputy sheriff. Because Edenfield was in jail when he made the incriminating statements, the trial court concluded that he was automatically entitled, without exception, to be read Miranda 1 warnings before any conversations with a law enforcement officer could occur. Because the trial court’s order relies on this incorrect legal assumption and lacks critical factual findings, we reverse and remand for further proceedings.

Although “[a]n appellate court reviewing a ruling on a…