Idaho v. Andersen

At approximately midnight on October 1, 2016, Coeur d’Alene police officers responded to an apartment after receiving a 911 call from defendant Brianna Andersen reporting that that “there was a male who was unconscious, not breathing and unresponsive in the bathroom area of the residence.” Paramedics arrived at the residence approximately five minutes after the police officers’ arrival. Andersen initially reported that the occupants of the residence had been downstairs in the basement eating pizza when the man went upstairs. Then “they heard a loud thump, and . . . they found him unconscious.” Police found the man still breathing, but surmised he may have been under the influence of heroin; a syringe for "a narcotic analgesic of some kind" was found on the sink nearby. Police aggressively questioned Andersen, with Andersen eventually offering she had flushed a syringe down the toilet prior to placing the 911 call because she did not want the man to get in trouble. Andersen consented to a search of her purse; the purse held two plastic baggies containing heroin. Andersen and a search of Andersen’s person revealed two syringe caps in her pocket. Andersen was charged by information with possession of heroin and destruction of evidence. Andersen filed a motion to suppress, contending that her statements were obtained in violation of her Miranda rights, that the physical evidence obtained as a result of the statements was “fruit of the poisonous tree,” and that the search of her purse was the product of coercion. The district court granted Andersen’s motion based on its finding that Andersen’s statements were made without Miranda warnings during a custodial interrogation and that Andersen’s statements were not voluntary. The Idaho Supreme Court determined Andersen was not in custody during her interrogation, and that her statements were not made involuntarily. Accordingly, the Supreme Court reversed. View "Idaho v. Andersen" on Justia Law