By: Derek Hawkins//February 15, 2018//
WI Court of Appeals – District IV
Case Name: State of Wisconsin v. Steve A. Brown
Case No.: 2017AP291-CR
Officials: Lundsten, P.J., Kloppenburg and Fitzpatrick, JJ.
Focus: Motion to Suppress – 6th Amendment
Steve Brown appeals a judgment of conviction entered after a jury found him guilty of repeated acts of sexual assault of the same child. Brown’s sole claim on appeal is that the circuit court erred in denying his motion to suppress inculpatory statements made during a pre-arrest interview with law enforcement. Brown maintains that the statements were obtained in violation of his constitutional right against self-incrimination because they were made during a custodial interrogation without the warnings required by Miranda v. Arizona, 384 U.S. 436 (1966). Because we conclude that Brown was not in custody for purposes of Miranda when he made the inculpatory statements at issue, we affirm.