State v. Olson, 314 Mont. 402

Summary

The Montana Supreme Court reviewed Sharon Marie Olson’s appeal from the denial of her motion to suppress evidence after she pleaded guilty to criminal possession of dangerous drugs. The court held that statements Olson made to a detective during a custodial interrogation without Miranda warnings had to be suppressed, but concluded that the remaining information established probable cause for the search warrant and particularized suspicion for the investigative traffic stop. The court affirmed the judgment while reversing in part the suppression ruling.

Holdings

1. Olson was in custody and Detective Wells's statements were interrogation because they were reasonably likely to elicit an incriminating response. Because Olson was not given Miranda warnings, her statements violated the Fifth Amendment and Article II, Section 25, of the Montana Constitution and had to be suppressed.
2. The search-warrant application established probable cause to search Olson's vehicle even after Olson's unwarned statements were excised.
3. The officers had particularized suspicion to justify the investigative traffic stop of Olson's vehicle.

Questions Presented

1. Whether Detective Wells's statements to Olson constituted custodial interrogation requiring Miranda warnings and whether Olson's resulting statements had to be suppressed.
2. Whether the search-warrant application established probable cause after Olson's statements were excised.
3. Whether officers had particularized suspicion to justify the investigative traffic stop of Olson's vehicle.

Disposition

affirmed