State v. Putnam

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR. THE STATE OF SOUTH CAROLINA In The Court of Appeals The State, Respondent, v. Martina Putnam, Appellant. Appeal From Sumter County George C. James, Jr., Circuit Court Judge Unpublished Opinion No. 2011-UP-526 Submitted November 1, 2011 – Filed December 2, 2011 AFFIRMED Deputy Chief Appellate Defender Wanda H. Carter, of Columbia, for Appellant. Attorney General Alan Wilson, Chief Deputy Attorney General John W. McIntosh, Assistant Deputy Attorney General Salley W. Elliott, and Assistant Attorney General Mark R. Farthing, all of Columbia; and Solicitor Ernest A. Finney, III, of Sumter, for Respondent. PER CURIAM: Martina Putnam appeals her conviction for homicide by child abuse, arguing the trial court erred in denying her motion to suppress statements she made to police officers without Miranda[1] warnings in the waiting rooms of two hospitals where her baby was receiving treatment. We affirm[2] pursuant to Rule 220(b)(1), SCACR, and the following authorities: State v. Evans, 354 S.C. 579, 583, 582 S.E.2d 407, 409 (2003) ("Appellate review of whether a person is in custody is confined to a determination of whether the ruling by the trial [court] is supported by the record."); State v. Navy, 386 S.C. 294, 301, 688 S.E.2d 838, 841 (2010) ("Whether a suspect is in custody is determined by an examination of the totality of the circumstances, such as the location, purpose, and length of interrogation, and whether the suspect was free to leave the place of questioning."); id. (stating the determination of custody is objective, namely "would a reasonable person have believed he was in custody"); State v. Easler, 327 S.C. 121, 128, 489 S.E.2d 617, 621 (1997) ("The initial determination of whether an individual was in custody depends on the objective circumstances of the interrogation, not the subjective views harbored by either the interrogating officers or the person being questioned."). AFFIRMED. SHORT, WILLIAMS, and GEATHERS, JJ., concur. [1] Miranda v. Arizona, 384 U.S. 436 (1966). [2] We decide this case without oral argument pursuant to Rule 215, SCACR.