SATTERFIELD v. STATE (2025)

MEMORANDUM DECISION

Statement of the Case

[1] During a traffic stop, Ashsten Satterfield admitted that a vape pen on the vehicle's dashboard was his and contained THC. When law enforcement officers searched the vehicle, they discovered fentanyl, which Satterfield also admitted was his. Satterfield was charged with and convicted of possession of a narcotic drug. Satterfield now appeals, raising one issue for our review: Whether the trial court abused its discretion by admitting certain evidence at trial.

[2] We affirm.

Facts and Procedural History

[3] On August 25, 2023, Officer Brandon Wilcox of the Beech Grove Police Department was on duty when he observed a man and a woman at a gas station behaving “kind of erratic,” “hanging around the gas station,” and repeatedly getting “in and out of the[ir] vehicle” for approximately 20 minutes. Tr. Vol. II at 27. Officer Wilcox checked the vehicle's license plate and discovered the vehicle's registered owner was Francesca Straw—the woman he was watching at the gas station—and she had an active arrest warrant. When the vehicle left the gas station, Officer Wilcox followed and observed it make an illegal U-turn, prompting him to initiate a traffic stop.

[4] Once Straw pulled over, Officer Wilcox exited his vehicle and approached the passenger side of Straw's vehicle. Satterfield was sitting in the front passenger seat. Because it was dark out, Officer Wilcox used his flashlight to see inside Straw's vehicle. After explaining why he pulled Straw over, Officer Wilcox asked Straw for her identification, vehicle registration, and proof of insurance. Straw initially began searching for the requested documents, but Satterfield took over doing so shortly thereafter; meanwhile, Officer Wilcox asked if there were any drugs or weapons in the vehicle, to which Satterfield responded, “No, sir.” State's Ex. 1 at 01:57–2:02.

[5] Straw advised Officer Wilcox that there was likely a warrant for her, but that the warrant was the result of someone else stealing her vehicle and identity in 2017. While this conversation was happening, Satterfield was searching through Straw's glove compartment, and when he finished, he placed several items on the dashboard above it, including a vape pen. Once Straw finished explaining her warrant situation, Officer Wilcox asked Straw and Satterfield what they were doing at the gas station, and they said that Straw had just gotten off work and they were headed to the gym. Officer Wilcox then shined his flashlight on the vape pen and asked, “What kind of pen is that right there?” State's Ex. 1 at 04:05–04:11. Satterfield stated it was his pen, and Officer Wilcox then asked if it was “a THC one,” to which Satterfield responded, “Yeah.” Id. Officer Wilcox requested Satterfield hand him the vape pen, and Satterfield complied.

[6] Officer Wilcox then asked for and reviewed Satterfield's identification before again asking about any drugs in the vehicle, noting that the “THC pen is definitely drugs.” State's Ex. 1 at 04:59–05:06. Satterfield said there were no other drugs in the vehicle. Officer Wilcox then requested consent to search Straw's vehicle and explained that he had probable cause to do so regardless of Straw's consent. Both Straw and Satterfield then exited the vehicle, were frisked, and were told to sit on the curb where Officer Wilcox read them their Miranda rights. Officer Cody Brozyna—who arrived on scene shortly before Straw and Satterfield exited the vehicle—searched the vehicle and found fentanyl. Satterfield told Officer Wilcox the fentanyl was his: “It literally is mine. It is mine.” Id. at 11:11–11:16.

[7] For his possession of fentanyl, the State charged Satterfield with possession of a narcotic drug as a Level 6 felony. Before trial, Satterfield filed a motion based upon several constitutional rights to suppress his admission that his vape pen contained THC, among other evidence. After a hearing, the trial court denied that motion. At trial, Satterfield objected to evidence related to his statement based on his motion to suppress, and the trial court overruled those objections. The jury found Satterfield guilty as charged. The trial court sentenced Satterfield to 360 days all suspended with no probation, and it ordered him to complete substance abuse treatment, successful completion of which could result in an alternative misdemeanor sentence. This appeal ensued.

Discussion and Decision

The Trial Court Did Not Abuse Its Discretion by Admitting Certain Evidence at Trial

[8] Satterfield claims that the trial court abused its discretion by admitting certain evidence at trial. We review rulings on admissibility of evidence for an abuse of discretion. Russell v. State, 234 N.E.3d 829, 858 (Ind. 2024) (quoting Conley v. State, 972 N.E.2d 864 (Ind. 2012)), cert. denied, 145 S.Ct. 424 (2024). We will reverse “only where the decision is clearly against the logic and effect of the facts and circumstances,” id. (quoting Smith v. State, 754 N.E.2d 502, 504 (Ind. 2001)), and “we may affirm the trial court's decision on any basis supported by the record,” Means v. State, 201 N.E.3d 1158, 1163 (Ind. 2023) (citing Ramirez v. State, 174 N.E.3d 181, 190 n.2 (Ind. 2021)). Where, as here, “a challenge to an evidentiary ruling is based on the constitutionality of the search or seizure of evidence, it raises a question of law that we review de novo.” Combs v. State, 168 N.E.3d 985, 990–91 (Ind. 2021) (internal quotation marks omitted) (quoting Johnson v. State, 157 N.E.3d 1199, 1203 (Ind. 2020), cert. denied), cert. denied.

[9] Satterfield specifically challenges the trial court's admission of his statement to Officer Wilcox confirming that his vape pen contained THC, claiming his statement was elicited in violation of his rights under the Fifth Amendment to the United States Constitution and Article 1, Section 14 of the Indiana Constitution. Those provisions “protect an individual's privilege against self-incrimination and ensure that only their voluntary statements can be used against them in a criminal prosecution.” J.Q.R. v. State, 252 N.E.3d 919, 924 (Ind. 2025) (citing U.S. Const. amends. V, XIV, § 1; Ind. Const. art. 1, § 14; D.M. v. State, 949 N.E.2d 327, 332–33 (Ind. 2011)). To that end, a law enforcement officer is obligated to give a person Miranda warnings when the person is under custodial interrogation. B.A. v. State, 100 N.E.3d 225, 230 (Ind. 2018) (citing Miranda v. Arizona, 384 U.S. 436, 444 (1966)).

[10] Satterfield argues that he was under custodial interrogation when Officer Wilcox asked if the vape pen contained THC. Miranda is triggered only if the person is subject to “custodial interrogation.” State v. E.R., 123 N.E.3d 675, 679 (Ind. 2019). “ ‘Interrogation’ for purposes of Miranda constitutes questions, words, or actions that the officer knows or should know are reasonably likely to elicit an incriminating response.” State v. Brown, 70 N.E.3d 331, 335 (Ind. 2017) (citing White v. State, 772 N.E.2d 408, 412 (Ind. 2002)).

[11] “Custody” under Miranda occurs when two criteria are met: (1) “the person's freedom of movement is curtailed to the degree associated with formal arrest” and (2) “the person undergoes the same inherently coercive pressures as the type of station house questioning at issue in Miranda.” State v. Diego, 169 N.E.3d 113, 117 (Ind. 2021) (quoting E.R., 123 N.E.3d at 680). To determine whether a person's freedom of movement was curtailed akin to formal arrest,

we examine the totality of objective circumstances surrounding the interrogation, including “the location, duration, and character of the questioning; statements made during the questioning; the number of law-enforcement officers present; the extent of police control over the environment; the degree of physical restraint; and how the interview begins and ends.”

Id. (quoting E.R., 123 N.E.3d at 680). A person who has been temporarily detained in an ordinary traffic stop is typically not in custody for the purposes of Miranda under either the United States or the Indiana Constitutions. Brown, 70 N.E.3d at 336 (citing Pennsylvania v. Bruder, 488 U.S. 9, 10 (1988); Meredith v. State, 906 N.E.2d 867, 873–74 (Ind. 2009)). However, a traffic stop may turn into a custodial situation. Crocker v. State, 989 N.E.2d 812, 818 (Ind. Ct. App. 2013) (quoting Lockett v. State, 747 N.E.2d 539, 543 (Ind. 2001)), trans. denied.

[12] Assuming arguendo that Officer Wilcox's questions, words, or actions constituted an interrogation, we cannot say that Satterfield was in custody such that he was subject to a custodial interrogation when Officer Wilcox asked about the vape pen's contents. Satterfield was initially detained pursuant to a traffic stop. Approximately three minutes into the traffic stop, while Officer Wilcox was waiting on Straw to produce her vehicle registration and proof of insurance, Satterfield placed his vape pen on the vehicle dashboard. A minute later, Officer Wilcox asked Satterfield about the vape pen, at which point Satterfield admitted it was his and contained THC. There is nothing about these circumstances suggesting that Satterfield's freedom of movement was curtailed to the degree associated with formal arrest or that the same inherently coercive pressures as the type of station house questioning at issue in Miranda were at play. See Diego, 169 N.E.3d at 118–20 (concluding defendant not in custody when questioned in interview room by armed officer because atmosphere was casual, questions were exploratory and conversational, and there was a relatively unimpeded pathway to the room). At the time Satterfield answered Officer Wilcox's questions about the vape pen, Satterfield was only temporarily detained pursuant to a routine traffic stop that had not yet turned custodial. See Meredith v. State, 906 N.E.2d 867, 874 (Ind. 2009) (concluding traffic stop was not custodial where defendant was stopped for traffic infraction and officer asked for defendant's license, to perform sobriety test based on observation of defendant, and for consent to search vehicle).

[13] Based on the foregoing, Satterfield was not in custody for the purposes of Miranda under either the United States or the Indiana Constitutions when he admitted his vape pen contained THC, so Miranda was not yet triggered. As such, Satterfield's statement was not elicited in violation of his rights under the Fifth Amendment to the United States Constitution and Article 1, Section 14 of the Indiana Constitution. The trial court thus did not abuse its discretion by admitting Satterfield's statement into evidence at trial, and we affirm the trial court's decision.

[14] Affirmed.

Felix, Judge.

Mathias, J., and Foley, J., concur.