People v. Zuccarini

In People v. Zuccarini, 172 Mich App 11; 431 NW2d 446 (1988), the Court applied the above principles and found that the defendant was lawfully detained, and not arrested, during the execution of a search warrant at his home. Id. at 13-14. In that case, the defendant was detained and handcuffed during the execution of a search warrant at his home. The defendant was detained while the police were attempting to gain control over the area to be searched. The defendant was handcuffed mainly for safety reasons and because the officers heard what sounded like other people running inside the house. The defendant was then advised of his Miranda rights and afterward showed the officers where the cocaine was located. Id. at 14. The defendant argued that his statements regarding the location of the cocaine should have been suppressed as the "fruit of the poisonous tree" stemming from his illegal arrest. Id. at 13. However, the Court held that the handcuffing of the defendant was a reasonable, limited intrusion of his liberty under the circumstances and that the fact that the defendant was advised of his Miranda rights did not necessarily mean that he was under arrest. Id. at 14-15. Thus, the Court affirmed the trial court's finding that the defendant was not arrested and his statements were not inadmissible as the fruit of an illegal arrest. Id. at 15.