Missouri Court of Appeals, Southern District / Nov 30, 2023
STATE OF MISSOURI, Plaintiff-Appellant vs. KRISTINA PROCTOR, Defendant-Respondent
Kristina Proctor was charged with driving while intoxicated, and the trial court suppressed her breath test result because law enforcement read her Missouri's Implied Consent Statements before her Miranda rights. The State of Missouri filed an interlocutory appeal. The appellate court reversed the suppression order, holding that Miranda warnings are not required before reading implied consent statements and requesting a breath test, as this process does not constitute a guilt-seeking interrogation. Consequently, the breath test result is admissible evidence.