In State v. Munn, 56 S.W.3d 486 (Tenn. 2001), the defendant, a suspect in the murder of his college roommate, arrived at the police station accompanied by his parents and was placed in an interview room with a tape recorder on the table. The room was also equipped with a hidden video camera and hidden microphones. Id. at 488-89.
After being questioned, the defendant asked the interrogating officers to turn off the tape recorder, which they did. The officers then asked the defendant's mother if she wanted to speak with the defendant "by himself."
When she said yes, the officers excused themselves from the room and closed the door, leaving the defendant and his mother alone. The defendant subsequently made incriminating statements, which were secretly recorded. Id. at 494-96.
The Tennessee Supreme Court held that the officers' actions created a subjective, reasonable expectation of privacy in the interview room, and that the trial court erred in failing to suppress the recorded statements. Id. at 496, 502.