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Oregon Supreme Court—November 30, 2017

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by: Mary A. Sell • December 6, 2017 • no comments

Written by Erin Severe, OPDS | Edited by Mary A. Sofia, OCDLA

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Motion to Suppress—Preservation

When defendant moved to suppress all statements he made during an encounter with police, and trial court’s ruling only addressed suppression of defendant’s post-Miranda statements, defendant not required to again request suppression of pre-Miranda statements to preserve that issue for appeal.

State v. Schmidtke, 362 Or 203 (2017) (Per Curiam)