State v. Hieu Tran

¶ 1. This interlocutory appeal raises the question of whether defendant Hieu Tran was in police custody when two detectives questioned him in a police cruiser for one hour as part of an investigation into an assault and attempted robbery. The trial court concluded that the interview was a custodial interrogation conducted without the warnings guaranteed by Miranda v. Arizona, 384 U.S. 436 (1966), and granted defendant’s motion to suppress. On appeal, the State argues that no warnings were necessary because defendant voluntarily spoke with detectives and was not in custody during the…