No. 1 Case Studies Examples

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The State of Ohio v. Farris, Supreme Court of Ohio, Decided: July 12, 2006, No. 2004-0604.

Statement of Facts

The suspect Stephen Farris was pulled over by a state trooper for speeding. The officer smelt burnt marijuana but found no drugs after a pat down search on the suspect. Without reading the Miranda rights, the officer asked the suspect if there were any drugs in the car to which the suspect denied. The officer then read the suspect his Miranda rights, asked the suspect the question again about the presence of drugs and then conducted a warrantless search of the car where he found drug paraphernalia in the trunk.

Procedural History

Farris filed a motion for the suppression of his testimony obtained both before and after the reading of Miranda rights and the evidence obtained from the warrantless search at the County Municipal Court. Only the testimony obtained before the reading of the Miranda rights was suppressed. The 9th District Court of Appeals upheld the decision. The Supreme Court overruled the decision and suppressed all evidence.

Issues

Is the testimony obtained before reading Miranda rights admissible in court? Was there enough probable cause for the trooper to search Farris’ car trunk?

Judgment

The Supreme Court ruled that both the pre and post-Miranda admission by the suspect about the possession of drug paraphernalia were inadmissible. The Supreme Court overturned the decision of the appellate court and ruled that the faint aroma of marijuana that prompted the warrantless search was not enough probable cause, and any obtained evidence was inadmissible from this search was inadmissible.

Holding

Testimony obtained from a suspect who believe she is in officer’s custody and whose Miranda rights have not been read is inadmissible. The faint marijuana smell in the car was not enough probable cause to conduct a warrantless search on the suspect’s car.

Rule of Law

The Fifth Amendment does not bar or outlaw the admission of statements made by a suspect who has not been warned of his Miranda rights. Section 10, Article I of the Ohio Constitution, however, bars such evidence and, in this case, it offers greater protection to defendants than the 5th amendment of the Constitution.

Reasoning

Since Section 10, Article I of the Ohio Constitution offers greater protection to defendants than the 5th amendment of the Constitution, testimony obtained before administration of Miranda rights is inadmissible.

No. 2

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The STATE of Ohio v. FARRIS, Supreme Court of Ohio, Decided: July 12, 2006, No. 2004-0604.

Statement of facts

A state trooper asked questions to the defendant who had stopped for speeding, about the presence of drugs in his car after he detected a smell of marijuana without reading him his Miranda rights. The defendant said that he was only in possession of a pipe and cigarettes, answers that he repeated even after the officer read him his Miranda rights. And asked him the questions again. The trooper in association with another officer conducted a search without a warrant on the defendant’s a car including its trunk using the smell of marijuana as probable cause where they found drug paraphernalia.
Procedural History
Apart from the testimony obtained before the reading of the Miranda rights, the county court admitted all other evidence and testimony and the defendant was given a $150 fine and his driving license was suspended. The decision was upheld by 9th District Court of Appeals, but the Supreme Court overturned this decision.
Issues
Should all evidence and testimony obtained from a suspect before has been read his Miranda Rights be admitted in court? Does the intentional withholding of the Miranda rights by an officer in order to obtain the defendant’s statement first constitute an infringement of the defendant’s rights? Should similar testimony obtained after the rights have been read be admitted in court?
Judgment
The testimony obtained both before and after the administration of the Miranda rights was inadmissible, and so was the evidence obtained from the warrantless search.

Holding

Testimony and evidence that has been obtained prior to the reading of Miranda rights cannot be admitted in court of law and the intentional failure to read these rights in order to obtain the same testimony from the client after the reading of the Miranda rights renders the second set of testimony also inadmissible.

Rule of Law

Greater protection is offered to criminal defendants by the Section 10, Article I of the Ohio Constitution than the Fifth Amendment meaning that evidence seized after unwarned statements from the defendant cannot be admitted.

Reasoning

The officer failed to read the Miranda rights to the defendant before obtaining his first set of testimony and due to the protection given by the Section 10, Article I of the Ohio Constitution, this testimony was inadmissible and since the same answers were given even after the rights were read, the second of statements was also inadmissible.

No. 3

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The STATE of Ohio v. FARRIS, Supreme Court of Ohio, Decided: July 12, 2006, No. 2004-0604.
Statement of Facts
The defendant was stopped by a state trooper on a highway for speeding. Detecting a faint aroma of marijuana, a search on the suspect revealed no drugs. The officer informed the defendant that he was going to search the car and without reading him his Miranda rights. He asked if it had any drugs to which the defendant denied but mentioned the presence of paraphernalia (some pipes and cigarettes). The trooper then read the Miranda rights, asked the defendant the previous questions, and the defendant provided similar answers. A warrantless search ensued where the trooper accompanied by another officer found a glass pipe and several cigarette rolling papers in the trunk of the defendant’s car.
Procedural History
The county court had admitted the testimony obtained after the defendant had been read his Miranda rights and suppressed the one obtained before administration of Miranda rights. This court had also admitted the evidence obtained in the defendant’s car trunk after the warrantless search. The District Court upheld the decision of this court including the defendant’s driver’s license suspension of 6 months and his $150 fine. The Supreme Court overturned the decision by declaring both statements before and after the reading of Miranda rights as inadmissible and also declared the warrantless search on the defendant’s car trunk illegal since the aroma of marijuana is not enough probable cause to conduct a warrantless search.
Issues
Is the defendant’s testimony obtained before he has been warned of his Miranda rights admissible? Is the smell and aroma of illegal drugs enough probable cause to conduct a warrantless search?
Judgment
According to the Supreme Court, both the evidence obtained before and after the reading of the Miranda rights were inadmissible. The trooper also did not have probable cause to conduct the warrantless search and the evidence obtained was thus inadmissible.
Holding
Testimony obtained from a defendant before he has been read his Miranda rights is not admissible. The smell and aroma of illegal drugs does not qualify as enough probable cause to conduct a warrantless search on the defendant’s car trunk although it qualifies a search in the car’s interior.
Rule of Law
The Fifth Amendment is not clear on the admissibility of testimony obtained before reading of the Miranda rights, and this evidence may be admitted. However, Section 10, Article I of the Ohio Constitution gives greater protection to the defendant therefore trampling the Fifth Amendment and rendering any evidence obtained before reading of Miranda rights inadmissible.

Reasoning

Section 10, Article I of the Ohio Constitution that gives greater protection to defendants renders any testimony obtained prior the reading of Miranda rights inadmissible. The testimony after Miranda rights was also inadmissible since the trooper intentionally delayed administration of the Miranda so that defendants could possibly admit guilt first.

No. 4

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The State of Ohio v. Farris, Supreme Court of Ohio, Decided: July 12, 2006, No. 2004-0604.
Statement of Facts
A state trooper apprehended Mr. Stephen Farris, the defendant on a state highway for speeding. After detecting the smell of marijuana, the trooper proceeded to question the defendant without reading him his Miranda rights but later read him the rights and questioned him again. The trooper also searched the defendant’s car interior and trunk without a warrant and found some drug paraphernalia.
Procedural History
The judges at the county and the appellate court ruled that the testimony obtained from the defendant after being read his Miranda rights and that the paraphernalia found in his car’s trunk was also admissible since the smell of marijuana was enough probable cause to warrant a search in the car’s trunk. These decisions were overturned by the Supreme Court of Ohio which rejected both the testimony and the evidence.
Issues
Should the testimony obtained from a client before he has been warned of his Miranda rights be admitted in court? Does a probable cause in a warrantless search place any limits or restrictions on the search itself?
Judgment
The Supreme Court of Ohio rule the testimony obtained from the defendant before he was warned of his Miranda rights was invalid and since he gave the same testimony after being read the Miranda rights, this testimony was also invalid. The evidence obtained from the car’s trunk was also ruled as inadmissible.
Holding
If a client give any testimony or makes statements before he has been warned of his Miranda rights, this testimony or these statements cannot be used in court. Probable cause only allows a warrantless search to take place within the immediate vicinity. In this case, the smell of marijuana only allowed the trooper to search the car’s interiors but not its trunk.
Rule of Law

The Supreme Court cited Section 10, Article I of the Ohio Constitution when making its ruling.

Reasoning
Section 10, Article I of the Ohio Constitution is more powerful in the state of Ohio that the Fifth Amendment in the national constitution and consequently, it is presumed to offer more protection to a criminal defendant and in this case, the provisions of the act means that the testimony obtained from Farris was read his Miranda rights was inadmissible and also that the search on his car’s trunk was illegal and anything found there could not therefore be used in court.
Works Cited