People v. Peerenboom

In People v. Peerenboom, 224 Mich App 195, 197; 568 NW2d 153 (1997), the defendant allegedly placed a bomb outside an occupied home. When the bomb did not detonate, the defendant retrieved the bomb. The bomb exploded in the car, and the defendant was severely injured. The defendant asserted that statements made by her to police must be suppressed because police officers did not provide her with Miranda warnings. The defendant had made statements to police officers during three interviews in her hospital room after the incident. The Court held that Miranda warnings were not required: Defendant had not been arrested at the time of these statements. An officer's obligation to give Miranda warnings to a person attaches only when the person is in custody, meaning that the person has been formally arrested or subjected to a restraint on freedom of movement of the degree associated with a formal arrest. "It is axiomatic that Miranda warnings need only be given in cases involving custodial interrogations." Thus, the trial court properly refused to suppress the statements on the basis of the officers' failure to give Miranda warnings because defendant had not been arrested at the time of the interviews and no formal restraint had been placed on her freedom of movement. Id. at 197-198.