State v. Maile

The justice court properly denied Defendant’s motion to suppress evidence obtained during the interrogation of Defendant by Montana Fish, Wildlife, and Park (FWP) game wardens at a game check station.Defendant was charged with license, permit or tag offense; unlawful possession, transfer, or transport of game animal; and hunting or killing of a game animal over the legal limit. Defendant moved to suppress evidence gathered at the FWP check station, asserting that his incriminating statements were the fruits of an illegal interrogation. The justice court concluded that Defendant was not required to receive Miranda warnings because he was not subject to custodial interrogation at the check station. Defendant was then found guilty on all three counts. The district court affirmed. The Supreme Court affirmed, holding (1) Defendant was not taken into custody for purposes of Miranda, and therefore, the statements he made to FWP game wardens were admissible against him; and (2) under the totality of the circumstances, Defendant’s admissions and confession were voluntary. View "State v. Maile" on Justia Law