Law Enforcement Bulletin

Sign up for newsletters and other news
Media > Newsletters > Law Enforcement Bulletin > April 2016 > State v. Martin, 2016 Ohio 802

Law Enforcement Bulletin RSS feeds

State v. Martin, 2016 Ohio 802

Question: Does a statement by a suspect who admits to have been drinking, render it involuntary and inadmissible in court?

Quick Answer: No. In determining whether a statement is voluntary, courts employ a “totality of the circumstances” test.

Facts: Martin observed a 9-year-old playing hide-and-seek outside with a friend. When she was alone, Martin lured her into his apartment. Once inside the apartment, he engaged in sexual activity with the child. When the minor returned home she informed her mother, who called the police. Officers brought Martin to the police station, read him Miranda, and he agreed to speak with them. During his statement, he told officers he was drinking beer and wine that day. He was asked if he was under the influence, and he said he was not. Prior to trial, Martin filed a motion to suppress his statement alleging it was involuntary. The trial court denied the motion, and Martin was convicted at trial.

On appeal, he argued his motion to suppress was improperly denied because his statement was involuntary due to his intoxication. The appeals court noted that in order to determine whether a defendant's statement is made voluntarily, courts employ a “totality of the circumstances” test. The officer’s testimony at the hearing was that Martin was alert, did not slur his speech, and his answers to questions, although self-serving and evasive, were appropriate. A review of the video recording of the interrogation also supported these observations. The court found there was sufficient evidence that Martin’s statement was not rendered involuntary based on intoxication.

Keep in Mind: It is important for officers to note their observations of a suspect during an interview. In this case, having a video-recorded interview supported the officer’s conclusion that the suspect’s statement was not compromised due to his level of intoxication.