State v. Bartelt

Lester Bartelt (defendant) was a suspect in an attack on a woman in a park and in the murder of Jessie Blodgett, Bartelt’s former girlfriend. The police told Bartelt that they were investigating an incident and asked Bartelt to come to the station. After arriving at the station, Bartelt was interviewed by two police officers. The police did not search Bartelt and told Bartelt that he was not under arrest and could leave at any time if he wanted, but they did not read Bartelt his Miranda rights. The officers questioned Bartelt about the park attack. The interview was conversational in tone, and neither officer spoke aggressively or confrontationally. After about 30 minutes of questioning, Bartelt confessed to the attack in the park. After this confession, the officers continued to ask Bartelt for details about the attack, until Bartelt asked if he could speak to a lawyer. At that point the officers stopped the interview and arrested Bartelt. On the following day, Bartelt was questioned about Blodgett’s murder. Bartelt was read his Miranda rights, which Bartelt waived. Bartelt asked for an attorney after about 90 minutes of questioning, and the interview was stopped. Evidence linking Bartelt to Blodgett’s murder was discovered based on statements Bartelt gave in that interview. Bartelt was indicted on numerous charges for the attack and Blodgett’s murder. Bartelt moved to suppress all of his statements and any evidence derived from them on the grounds that he had not been read his Miranda rights during the first interview. The circuit court denied Bartelt’s motion on the grounds that Bartelt had not been in custody until he asked for an attorney after his confession. The charges for the two crimes were separated, and Bartelt was convicted of Blodgett’s murder. Bartelt appealed on the grounds that the court had improperly denied his suppression motion. The court of appeals affirmed the circuit court’s judgment. Bartelt’s request for review was granted.