{
  "id": 220143,
  "name": "STATE OF NORTH CAROLINA v. RODNEY DALE BUCHANAN",
  "name_abbreviation": "State v. Buchanan",
  "decision_date": "2002-03-07",
  "docket_number": "No. 190A00-2",
  "first_page": "264",
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    "name": "Supreme Court of North Carolina"
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      "year": 2001,
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          "parenthetical": "holding that the \"ultimate inquiry\" test shall be used to determine whether an individual is in custody for purposes of Miranda warnings"
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  "last_updated": "2023-07-14T16:24:10.729326+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
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  "casebody": {
    "judges": [],
    "parties": [
      "STATE OF NORTH CAROLINA v. RODNEY DALE BUCHANAN"
    ],
    "opinions": [
      {
        "text": "PER CURIAM.\nDefendant, indicted on two counts of first-degree murder, initially filed a pretrial motion requesting that the trial court suppress statements he made during a station house interview with police. After conducting a hearing on the issue, the trial court ruled that during the interview, defendant was in custody for purposes of Miranda warnings. As a result, the trial court ordered all statements made by defendant prior to being given such warnings excluded from trial.\nOn appeal by the State, this Court held that the trial court used the wrong test in its attempt to determine whether defendant was in custody for purposes of Miranda warnings, and ordered the trial court to reconsider the issue under the proper test. State v. Buchanan, 353 N.C. 332, 543 S.E.2d 823 (2001) (holding that the \u201cultimate inquiry\u201d test shall be used to determine whether an individual is in custody for purposes of Miranda warnings). On remand, the trial court, following our mandate, added two findings of fact to its previous findings and reassessed defendant\u2019s circumstances under the proper test. The trial court then concluded that a reasonable person in defendant\u2019s position would have believed he was in custody\u2014 \u201crestrained in his movement to the degree associated with a formal arrest,\u201d id. at 340, 543 S.E.2d at 828 \u2014 when, after admitting to his station house interrogators that he had participated in a homicide, those same interrogators accompanied him to the bathroom, with an officer staying with defendant at all times. As a consequence of so concluding, the trial court suppressed any statements defendant made between the time he returned from the bathroom until Miranda warnings were properly administered. We affirm.\nA trial court\u2019s ruling on a motion to suppress is conclusive on appeal \u201cif [it is] supported by competent evidence.\u201d State v. Eason, 336 N.C. 730, 745, 445 S.E.2d 917, 926 (1994), cert. denied, 513 U.S. 1096, 130 L. Ed. 2d 661 (1995). In the case sub judice, the trial court properly applied the \u201cultimate inquiry\u201d test to the evidence as instructed by this Court. The new findings of fact were supported by competent evidence; therefore, the trial court\u2019s ruling is conclusive on appeal.\nAFFIRMED.",
        "type": "majority",
        "author": "PER CURIAM."
      }
    ],
    "attorneys": [
      "Roy Cooper, Attorney General, by William P. Hart, Special Deputy Attorney General, for the State-appellant.",
      "Richard B. Schultz and Edgar F. Bogle for defendant-appellee."
    ],
    "corrections": "",
    "head_matter": "STATE OF NORTH CAROLINA v. RODNEY DALE BUCHANAN\nNo. 190A00-2\n(Filed 7 March 2002)\nConfessions and Incriminating Statements\u2014 defendant in custody \u2014 ultimate inquiry test \u2014 suppression of statements before Miranda warnings\nThe trial court properly applied the \u201cultimate inquiry\u201d test in determining that defendant was in custody when, after admitting to his station house interrogators that he had participated in a homicide, those same interrogators accompanied him to the bathroom, with an officer staying with defendant at all times; consequently, the trial court properly suppressed any statements defendant made between the time he returned from the bathroom until Miranda warnings were administered to him.\nAppeal pursuant to N.C.G.S. \u00a7 15A-979(c) from a suppression of evidence order entered 6 July 2001 by Beal, J., in Superior Court, Gaston County. Heard in the Supreme Court 10 December 2001.\nRoy Cooper, Attorney General, by William P. Hart, Special Deputy Attorney General, for the State-appellant.\nRichard B. Schultz and Edgar F. Bogle for defendant-appellee."
  },
  "file_name": "0264-01",
  "first_page_order": 312,
  "last_page_order": 313
}