Missouri Court of Appeals, Western District / Jun 12, 2018
State of Missouri vs. Genevieve Sueanne Craig
The State of Missouri appealed a circuit court order suppressing statements made by Genevieve Craig during the execution of a search warrant at her home. Craig, who was in custody but not yet Mirandized, made statements about brass knuckles, drug paraphernalia, and stolen tools. The circuit court suppressed all statements made after she was handcuffed and before Miranda warnings. The appellate court reversed, holding that Craig's statement about the brass knuckles was spontaneous and not the result of interrogation, and that the recitation of a search warrant is not inherently an interrogation. The case was remanded for the circuit court to determine whether Craig was subjected to interrogation under the specific circumstances.