State v. Fullerton, 2018 UT 49 (Sept. 11, 2018)

In this case involving an appeal from the denial of a motion to suppress statements the criminal defendant made during an interview with the police, the Utah Supreme Court addressed the proper standard for evaluating whether a person is involved in a “custodial interrogation” such that Miranda warnings are required.  In light of the evolution of United States Supreme Court precedent on this issue, the four factors articulated in Salt Lake City v. Carner, 664 P.2d 1168 (Utah 1983) cannot be considered exclusively.  Rather, proper use of the Carner factors requires “considering them in conjunction with all other relevant circumstances.” Each factor “should be considered when relevant, ignored when not, and given appropriate weight according to the circumstances.”