State v. Logsdon

2025 Ohio 298
CourtOhio Court of Appeals
DecidedJanuary 31, 2025
Docket30290
StatusPublished
Cited by1 cases

This text of 2025 Ohio 298 (State v. Logsdon) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Logsdon, 2025 Ohio 298 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Logsdon, 2025-Ohio-298.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

STATE OF OHIO : : Appellant : C.A. No. 30290 : v. : Trial Court Case Nos. 2024-CRB- : 00209; 2024-TRD-000326 JERRY LOGSDON : : (Criminal Appeal from Municipal Court) Appellee : :

...........

OPINION

Rendered on January 31, 2025

MARK T. ROSS, Attorney for Appellant

ARVIN S. MILLER, Attorney for Appellee

.............

TUCKER, J.

{¶ 1} Plaintiff-appellant State of Ohio appeals from an order of the Dayton

Municipal Court that granted defendant-appellee Jerry Logsdon’s pretrial motion to

suppress evidence. For the reasons set forth below, we reverse and remand. -2-

I. Factual and Procedural History

{¶ 2} On December 28, 2022, Logsdon was involved in a motor vehicle collision

on Wayne Avenue; a pedestrian was killed, and Logsdon sustained serious injuries.

Following the collision, Logsdon was transported to Miami Valley Hospital, and he

underwent surgery the next day. On January 3, 2023, Dayton Police Department

Detective Christopher Jordan went to the hospital to interview Logsdon.

{¶ 3} On January 23, 2024, Logsdon was charged with vehicular homicide,

vehicular manslaughter, failure to control, and speeding. He filed a motion to suppress

his statements to Det. Jordan during the hospital interview. A hearing on the motion was

conducted on June 12, 2024. Jordan testified regarding the interview. The State

introduced the video of the interview retrieved from Jordan’s body camera, which was

worn and operating during the hospital interview.

{¶ 4} The video began with Jordan walking down the hallway of the hospital toward

Logsdon’s room. Jordan knocked on the door and was invited in. As Jordan walked

into the room, Logsdon was laying, slightly inclined, in the bed, and he was using the

hospital telephone. A woman, who was identified only as Logsdon’s friend, was also in

the room, and she remained in the room for the entire interview.

{¶ 5} Jordan immediately introduced himself and indicated he was there to

investigate the collision. Jordan asked Logsdon if he was able to speak with him.

Logsdon replied, “good timing,” and indicated that he was on the phone with his mother.

He then hung up the landline and instructed his friend to call his mother on her cell phone. -3-

The mother then was connected, on speaker, for the entirety of the interview.

{¶ 6} Logsdon immediately began speaking and stated, “the news said it was my

fault.” He then denied responsibility for the collision and claimed that a “Nissan” that was

“low to the ground” and had a “spoiler” had pulled in front of him and “cut [him] off.”

Logsdon stated that he had been able to engage his brakes but that he slid on “black ice.”

{¶ 7} At that point, Jordan informed Logsdon that the crash remained under

investigation. Jordon also stated that he needed to inform Logsdon of his rights before

asking him any questions. On the phone, Logsdon’s mother asked if Jordan was

arresting her son. Jordan explained that Logsdon was not being arrested and that it was

Jordan’s standard procedure to explain a person’s rights before questioning them.

Jordon then asked Logsdon for preliminary information including his social security

number, date of birth, address, phone number, and his mother’s phone number.

Logsdon provided the information without any hesitation and again reiterated that he was

not at fault for the accident. He also stated that he had completed high school but had

not graduated.

{¶ 8} Jordan provided Logsdon with a copy of a standard Miranda pre-interview

form so that he could follow along as Jordan recited from the form. After hearing each

enumerated right, Logsdon indicated his understanding of that right. Jordan then read

the waiver of rights portion of the form to Logsdon, which Logsdon signed.

{¶ 9} Jordan then produced four pre-printed pages of interview questions. Each

question had a space to write in Logsdon’s response. As Logsdon answered the

questions, Jordan filled out the pages with the information provided. Logsdon signed all -4-

four pages. Logsdon indicated that, at the time of the collision, he was driving at the

speed limit of 35 miles per hour. He indicated that he had been able to see clearly and

that he did not have any vision limitations. He also indicated that he had been wearing

his seat belt. According to Logsdon, he had just dropped off his mother at her home and

was heading to UDF to get beer for a friend when the crash occurred. He admitted he

did not have auto insurance. He stated that he had not consumed any alcohol and had

not smoked any marijuana.1 Logsdon stated that the Nissan that caused the collision

had been a gray/silver color and that it had been driven by a white male. After Logsdon

signed the questionnaire, Jordon answered some questions posed by Logsdon’s mother.

As Jordan was exiting the room, Logsdon made a joke about his injuries.

{¶ 10} The trial court sustained Logsdon’s motion to suppress the statements he

made during the hospital interview. Specifically, the trial court found that Logsdon had

been in custody at the time of the interview because he was “bed-ridden” and attached to

medical monitors. The court also found that Logsdon’s waiver of his rights was not

knowing, intelligent, and voluntary because he had invoked his right to an attorney and

was “substantially compromised” by his “pain” and by the pain medications he was taking.

{¶ 11} The State appeals.

II. Suppression

{¶ 12} The sole assignment of error asserted by the State is:

THE TRIAL COURT ERRED IN SUPPRESSING APPELLEE’S ORAL AND

1 During the interview, Logsdon stated, without prompting, that he smoked marijuana. -5-

WRITTEN STATEMENTS MADE TO DETECTIVE JORDAN.

{¶ 13} The State challenges the trial court’s decision to suppress Logsdon’s

statements to Jordan. The State argues that the trial court erred in finding that Logsdon

had been in custody at the time of the interview. The State further argues that the

evidence did not support the court’s finding that Logsdon’s waiver was not made

knowingly, voluntarily, and intelligently. Finally, the State contends that the court’s

finding that Logsdon had invoked his right to counsel was not supported on the record.

{¶ 14} We begin with by considering whether Logsdon was in police custody. In

Miranda v. Arizona, 384 U.S. 436 (1966), the United States Supreme Court adopted

procedural safeguards to secure the Fifth Amendment's constitutional guarantee against

self-incrimination. State v. Hudson, 2022-Ohio-3253, ¶ 30 (2d Dist.). “Miranda requires

police to give a suspect certain prescribed warnings before custodial interrogation

commences and provides that if the warnings are not given, any statements elicited from

the suspect through police interrogation in that circumstance must be suppressed.” State

v. Petitjean, 140 Ohio App.3d 517, 523 (2d Dist. 2000).

{¶ 15} Miranda warnings are required only when police conduct a custodial

interrogation. Hudson at ¶ 31. A custodial interrogation occurs when law enforcement

officers take a person “into custody or otherwise deprive [him] of his freedom of action in

any significant way.” State v.

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