Centre County Judge Reviews Miranda Issue in State College Assault Case


A Centre County judge recently considered whether or not to suppress statements made by two people to a police officer in a State College assault investigation. The officer responded to the reported fight in the wee hours of the morning in downtown State College, and, after arriving on scene, witnesses pointed out the two defendants as being the perpetrators of the assault. The officer proceeded after the suspects and ultimately detained them. A second officer arrived on scene to assist in the investigation. The suspects were questioned about their involvement in the assault, and, according to the Centre County court’s published opinion, the suspects denied participating in the fight. While the suspects denied being involved in the fight, witnesses again identified the suspects as being the assailants. The men were arrested and ultimately charged with Aggravated Assault, 18 Pa.C.S.A. § 2702; Simple Assault, 18 Pa.C.S.A. § 2701; and Recklessly Endangering Another Person, 18 Pa.C.S.A. § 2705. One the men was also charged with Underage Drinking, in violation of 18 Pa.C.S.A. § 6308.

Motion to Suppress Filed

The State College defense lawyers for the men filed a Motion to Suppress and argued that any statements that the men gave to the police officer were given in violation of their 5th Amendment right against self-incrimination. The basic argument was that the police had failed to provide the Penn State assault suspects with their Miranda warnings, and the failure violated the suspects’ constitutional rights and required the suppression of any incriminating statements that were made.

Many people mistakenly believe that Miranda warnings must be given when a person is arrested, a notion most likely a result of watching the COPS show during the 1990s. Miranda warnings are actually required to be given when a person is in “custody” and is being “interrogated.” An interrogation means questioning or statements that are reasonably likely to elicit an incriminating response. Here, if the officer asked the men if they were involved in the fight, such questions would constitute an “interrogation.” The issue in this case was whether the officer had actually placed the men in “custody.” Custody can occur  even if a person is not actually arrested and handcuffed. Here, the judge ultimately stated that the assault suspects were only detained by the State College police officers and were not actually in “custody.” Since the men were not in custody, the officer was not required to provide Miranda warnings. Since no constitutional violations occurred, the Centre County judge denied the pretrial motion to suppress filed by the criminal defense lawyers. Any statements made by the men will be admissible at the upcoming trial.