State v. Buchholz

In State v. Buchholz (1984), 11 Ohio St. 3d 24, 11 Ohio B. 56, 462 N.E.2d 1222, the Ohio Supreme Court noted the State did not raise the question of whether the defendant therein was in custody. The State's only argument was Miranda did not apply because the defendant was only convicted of a misdemeanor. Id., at pg. 26, FN. 2. The Ohio Supreme Court assumed the State conceded the defendant was in custody. Id.