State v. Conner, 2022-NCCOA-295, ___ N.C App. ___ (May. 3, 2022)

In this McDowell Countyt case of first impression, the Court of Appeals determined that law enforcement officers were not required to provide the defendant with Miranda warnings while he barricaded himself in a bedroom for many hours and threatened to commit suicide while officers served an arrest warrant for him at his aunt’s home.  Because the defendant was not in custody for Miranda purposes while barricaded in the bedroom, the court rejected his argument that un-warned incriminating statements he made indicating that there were drugs in the bedroom should be suppressed.  The court explained that the defendant’s own actions prevented officers from placing him in Miranda custody and noted that negotiations between the defendant and officers while he was barricaded were “limited to the purpose of having defendant safely leave the bedroom.”  The court vacated and remanded one judgment in the case for correction of a clerical error related to sentencing.