Aaron L. Fansler v. State of Indiana

In this case we address whether, under Indiana Evidence Rule 617, admission of incriminating statements made in a motel room 1 during the course of a custodial interrogation required the State to make available an electronic recording of those statements at trial. We find that the trial court did not err in admitting the defendant's statements without such a recording because the motel room in question was not a "place of detention," as defined by the rule.

Facts and Procedural History

On June 18, 2015, Aaron Fansler ("Fansler") accepted a Facebook friend request to connect with a user who…