The Constitution protects criminal defendants from self-incrimination, meaning they cannot be forced to make statements that could incriminate them. In many cases, even if a defendant makes statements suggesting guilt, those statements may be excluded from trial if the defendant was not properly informed of their rights before making them. The recent discussion of the standards for excluding incriminating statements came up in a Pennsylvania DUI case where the defendant was moved to suppress statements made before receiving a Miranda warning. If you’re facing DUI charges and have spoken to the police during their investigation, it’s advisable to consult with an experienced Pennsylvania DUI defense attorney to explore potential defenses that could help you avoid a conviction.
Factual and Procedural History
It is alleged that in September 2021, a police officer was conducting speed enforcement. He spotted a silver SUV traveling at 85 miles per hour in a 50-mile-per-hour zone and initiated a traffic stop. The driver of the SUV, the defendant, complied with the stop. The officer noticed a strong smell of burnt marijuana coming from the vehicle and inquired if the defendant had recently smoked, to which the defendant admitted he had smoked marijuana about 45 minutes before being stopped. A subsequent check revealed that the defendant’s driver’s license was suspended. Suspecting the defendant might be under the influence, the officer asked him to perform field sobriety tests, which showed signs of impairment.
It is reported that the defendant was charged with DUI. He filed a pretrial motion seeking suppression of his admission to marijuana use and subsequent blood test results, arguing that his rights under Miranda were violated as the purpose of the traffic stop had concluded. The trial court granted the suppression motion, concluding that the defendant was in custody at the time of the questioning, and thus, Miranda warnings were required. The Commonwealth appealed.
Miranda Warnings in DUI Cases
On appeal, the court reversed the trial court ruling. In doing so, the court emphasized that Miranda warnings are only required in custodial detentions, while traffic stops typically constitute investigative detentions. In this case, the initial stop was based on a valid speeding violation, and the trooper’s suspicion of DUI due to the strong marijuana odor provided reasonable suspicion for further investigation. The court held that the continued stop did not escalate to a custodial detention, as the defendant was not physically restrained, threatened, or transported from the scene. Therefore, the court found that Miranda warnings were not necessary before the trooper’s question about marijuana use and reversed the suppression order.
Confer with a Trusted Pennsylvania DUI Defense Attorney
If facing a DUI charge in Pennsylvania, it’s recommended to consult with a knowledgeable Pennsylvania DUI defense attorney to understand the potential evidence the prosecution might use in your trial. Attorney Zachary B. Cooper is a dedicated Pennsylvania DUI defense attorney who will vigorously work to achieve the best possible outcome for your case based on the circumstances surrounding your charges. You can contact Mr. Cooper through the online form or at (215) 542-0800 to arrange a free and confidential consultation.