Cleveland v. Oles (Slip Opinion)

{¶ 1} In this consolidated appeal, we address whether the Fifth Amendment to the United States Constitution and Article I, Section 10 of the Ohio Constitution require a law-enforcement officer to provide Miranda warnings to a suspect who has been placed in the front seat of a police vehicle for questioning during a traffic stop. We hold that the placement of a suspect in the front seat of a police vehicle during a traffic stop is not alone determinative of whether the suspect has been subjected to a custodial interrogation. The relevant inquiry is whether, under the totality of the…