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Criminal Law-DWI-Miranda Violation
Staff Report//February 18, 2026//
Defendant appealed his conviction for DWI, driving without insurance and speeding, arguing that the trial court erred in admitting statements he made during the traffic stop because he was in “custody” as his freedom of movement was curtailed and police failed to advise him of his Miranda rights.
Where the traffic stop was brief, conducted in public and only involved limited questioning, the stop only amounted to a Terry stop rather than a full arrest, making Miranda inapplicable.
Judgment is affirmed.
State v. Spates (MLW No. 84365/Case No. ED113216 – 9 pages) (Missouri Court of Appeals, Eastern District, Hess, J.) Appealed from circuit court, St. Charles County, Cornejo, J. (David R. Angle for appellant) (Charlene E. Stockman for respondent)
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