Recently, a state appellate court issued an opinion in a New York Leaving the Scene of an Accident case which required the court to analyze whether a defendant’s statements that were elicited before he was given his Miranda warnings were admissible at trial. Ultimately, the court held that, because the defendant was not in custody when he made the statements, the detective interviewing him did not need to Mirandize the defendant. Thus, the statements were admissible and the defendant’s conviction was affirmed.
The Facts of the Case
According to the facts contained in the appellate opinion, a pedestrian was struck by a pickup truck in East Islip. Throughout the course of the investigation, the detective got a lead that the defendant had a pickup truck that matched the description of the one that hit the pedestrian.
The detective went to the defendant’s home. When the detective arrived, he told the defendant why he was there, and the defendant voluntarily answered a few preliminary questions. The defendant also agreed to let the detective check out his vehicle.