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State v. Nelson

2026-08-21

Summary

Holding. The trial court properly denied Nelson's motion to suppress her statements made during police interrogation. The judgment of the trial court is affirmed.

Janel Nelson was suspected of murdering M.S. in Greene County, Ohio. After she traveled to Nebraska, local detectives located her at a homeless shelter in Omaha and asked her to come to the police station for questioning. Nelson was transported in handcuffs but was uncuffed and placed in an interview room upon arrival. She was read her Miranda rights, indicated she understood them, and agreed to speak with detectives. She was advised she was not under arrest and was free to leave. During the three-hour interview, Nelson was provided food, water, restroom access, and a smoking break. Nelson challenged the admissibility of her statements, claiming the encounter became non-consensual when she was handcuffed and that her statements were involuntary due to police deception.

The trial court denied Nelson's motion to suppress. On appeal, the appellate court examined whether Nelson's statements constituted custodial interrogation requiring Miranda warnings and whether the statements were voluntary. The court found that even if Nelson was in custody, she was properly advised of her Miranda rights, understood them, and knowingly waived those rights. The court also found no evidence that police coercion or deception overrode Nelson's will. The appellate court applied the totality of circumstances test and determined that the conditions surrounding the interview—including the conversational tone, provisions for her comfort, and absence of threats or false promises—supported the voluntary nature of her statements.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether handcuffing and transport to a police station converted a consensual encounter into custodial interrogation requiring Miranda warnings
  • Whether statements made after a knowing and intelligent waiver of Miranda rights are presumed voluntary
  • Whether police conduct involving deception can render a confession involuntary despite proper Miranda warnings

Procedural posture

Nelson appealed her conviction for murder and felonious assault following her no-contest plea after the trial court denied her motion to suppress statements she made during police questioning.

Authorities cited

Opinion

majority opinion

[Cite as State v. Nelson, 2026-Ohio-3266.]

IN THE COURT OF APPEALS OF OHIO

SECOND APPELLATE DISTRICT

GREENE COUNTY

STATE OF OHIO :

: C.A. No. 2025-CA-54

Appellee :

: Trial Court Case No. 2024 CR 0525

v. :

: (Criminal Appeal from Common Pleas

JANEL M. NELSON : Court)

:

Appellant : FINAL JUDGMENT ENTRY &

: OPINION

Pursuant to the opinion of this court rendered on August 21, 2026, the judgment of

the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

send a copy of the court’s ruling to each party and note that action on the docket.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

EPLEY, J., and HANSEMAN, J., concur.

OPINION

GREENE C.A. No. 2025-CA-54

ADAM J. ARNOLD, Attorney for Appellant

MEGAN A. HAMMOND, Attorney for Appellee

TUCKER, J.

{¶ 1} Defendant-appellant Janel M. Nelson appeals from her conviction of murder.

For the reasons set forth below, we affirm.

I. Factual and Procedural Background

{¶ 2} On August 22, 2024, the body of M.S. was discovered in his home in Greene

County, Ohio. It was determined that M.S. had been killed by a gunshot wound to the back

of his head. Following an investigation, Nelson was identified as a suspect, but it was

determined that she had left Ohio and traveled to Nebraska. Detective John Bondy of the

Beavercreek Police Department contacted Omaha Police Department Detective Ryan

Hinsley and asked him to help locate Nelson. Bondy provided a photograph of Nelson and

a list of Nelson’s family contacts in the Omaha area. He also advised that Nelson might be

located at a homeless shelter in the area. Bondy indicated that Nelson might be driving a

silver car with Wisconsin license plates.

{¶ 3} On August 26, 2024, Hinsley and another detective went to a local shelter,

where they observed a sedan matching the description provided by Bondy. A woman

matching Nelson’s photograph was observed walking out of the shelter and approaching the

sedan. Hinsley called out the name “Janel Neson” and the woman acknowledged that was

her name. Hinsley advised her that another agency wanted to speak to her concerning an

investigation, and he asked whether she would come to the Omaha Police Department to

meet with investigators. Nelson agreed.

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{¶ 4} A uniformed Omaha officer arrived to transport Nelson. Nelson was informed

that police department policy granted the officer the discretion to place her in handcuffs for

the transport. Nelson indicated that she understood the policy and stated that she was willing

to proceed. Nelson was placed in handcuffs. Her cell phone, purse, and car keys were taken

from her prior to transport.

{¶ 5} At the police department, Nelson was uncuffed and placed in an interview room.

Hinsley informed Nelson of her rights under Miranda v. Arizona, 384 U.S. 436 (1966). An

interview ensued, which was recorded.

{¶ 6} On October 25, 2024, Nelson was indicted on one count of murder in violation

of R.C. 2903.02(B) and one count of felonious assault in violation of R.C. 2903.11(A)(2).

Both counts carried a three-year firearm specification and a forfeiture specification. She was

extradited and returned to Ohio.

{¶ 7} In December 2024, Nelson filed a motion to suppress all statements made

during her interaction with the Omaha detectives. The motion was overruled.

{¶ 8} Following plea negotiations, Nelson agreed to plead no contest to the charge of

murder and its attendant firearm and forfeiture specifications. She further agreed to pay

restitution and the cost of extradition. In exchange, the State agreed to dismiss the remaining

charge and specifications. The plea agreement contained an acknowledgement that the trial

court was required to impose a sentence of life imprisonment with the possibility of parole

after 18 years of imprisonment. The trial court sentenced Nelson as set forth in the plea

agreement.

{¶ 9} Nelson appeals.

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II. Suppression

{¶ 10} Nelson asserts the following two assignments of error:

THE TRIAL COURT ERRED IN DENYING MS. NELSON’S MOTION

TO SUPPRESS STATEMENTS OF HER UNLAWFUL SEIZURE BY

OFFICER.

THE TRIAL COURT ERRED IN FINDING MS. NELSON’S

STATEMENTS WERE VOLUNTARY.

{¶ 11} Nelson argues that the trial court erred by not suppressing the statements she

made during her interview at the Omaha police station. She claims that the “encounter

between [herself] and law enforcement ceased to be consensual when officers handcuffed

her and transported her to the police station for investigative questioning,” and the interview

thus constituted a custodial interrogation necessitating warnings in accordance with Miranda

v. Arizona, 384 U.S. 436 (1966). She further claims that her statements to the police were

not voluntary, because the detectives engaged in deceptive practices during the interview.1

{¶ 12} When deciding a motion to suppress, the trial court “assumes the role of the

trier of fact, and, as such, is in the best position to resolve questions of fact and evaluate the

credibility of the witnesses.” State v. Retherford, 93 Ohio App.3d 586, 592 (2d Dist. 1994);

State v. Knisley, 2010-Ohio-116, ¶ 30 (2d Dist.). Accordingly, when this court reviews

suppression decisions, we must accept the trial court's findings of fact if they are supported

by competent, credible evidence. Retherford at 592. “Accepting those facts as true, we must

1. We note that on appeal Nelson asserts for the first time that the trial court should have granted the motion to suppress, because she was subjected to a de facto arrest when she was handcuffed, and also that the police lacked probable cause for her arrest. We need not address this argument as it was not raised before the trial court and thus not preserved for appellate review.

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independently determine as a matter of law, without deference to the trial court’s conclusion,

whether they meet the applicable legal standard.” Id.

{¶ 13} “The right to Miranda warnings is grounded in the Fifth Amendment’s

prohibition against compelled self-incrimination.” State v. Strozier, 2007-Ohio-4575, ¶ 16

(2d Dist.), citing Moran v. Burbine, 475 U.S. 412, 420 (1986). However, “police are not

required to give [Miranda] warnings to every person they question, even if the person being

questioned is a suspect.” State v. Hatten, 2010-Ohio-499, ¶ 49 (2d Dist.), citing State v.

Biros, 78 Ohio St.3d 426, 440 (1997). Miranda warnings are required only for custodial

interrogations. Strozier at ¶ 16. Miranda defined custodial interrogation as “questioning

initiated by law enforcement officers after a person has been taken into custody or otherwise

deprived of his freedom of action in any significant way.” Miranda at 444. Such an inquiry

“focuses upon how a reasonable person in the suspect’s position would have understood

the situation.” State v. Ferguson, 2017-Ohio-7930, ¶ 70 (2d Dist.), citing Berkemer v.

McCarty, 468 U.S. 420, 442 (1984). “[N]either the subjective intent of the officer, nor the

subjective belief of the defendant is relevant.” State v. Hatten, 2010-Ohio-499, ¶ 50

(2d Dist.).

{¶ 14} We have reviewed the transcript of the suppression hearing and the videotape

and transcription of the interview at the Omaha police department and conclude that

Nelson’s arguments lack merit. Irrespective of whether she was in custody for purposes of

Miranda, the record unequivocally demonstrates that she was properly advised of her

Miranda rights before she was interrogated. Nelson indicated that she understood each right

and that she was familiar with Miranda warnings, having been apprised of them in the past.

There is nothing in the record to indicate that Nelson was incapable of understanding the

warnings, or that she was under the influence of anything that may have impaired her ability

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to understand the warnings. In short, the record supports a finding that Nelson knowingly,

voluntarily, and intelligently waived her rights under Miranda.2

{¶ 15} Nelson also contends that her statements were not voluntarily made, because

the police engaged in deceptive acts during the interview.

{¶ 16} A defendant’s statements to police after a knowing, intelligent, and voluntary

waiver of his or her Miranda rights are presumed to be voluntary. E.g., State v. Porter, 2008-Ohio-4627, ¶ 13 (2d Dist.) (discussing Miranda). However, “[t]he Miranda presumption

applies to the conditions inherent in custodial interrogation that compel the suspect to

confess. It does not extend to any actual coercion police might engage in, and the Due

Process Clause continues to require an inquiry separate from custody considerations and

compliance with Miranda regarding whether a suspect's will was overborne by the

circumstances surrounding his confession.” Id. at ¶ 14, citing Dickerson v. United States,

530 U.S. 428 (2000).

{¶ 17} “In deciding whether a defendant’s confession is involuntarily induced, the

court should consider the totality of the circumstances, including the age, mentality, and prior

criminal experience of the accused; the length, intensity, and frequency of interrogation; the

existence of physical deprivation or mistreatment; and the existence of threat or

inducement.” State v. Edwards, 49 Ohio St.2d 31 (1976), paragraph two of the syllabus,

rev’d on other grounds, 438 U.S. 911 (1978).

{¶ 18} After Nelson was transported to the police station, she was placed in an

interview room and the handcuffs were removed. She was advised that she was not under

2. While Nelson correctly notes that she was asked questions for a few minutes prior to the administration of the warnings, those questions were merely preliminary background questions such as name, address, and age. Such routine background questioning is not required to be prefaced by Miranda warnings. State v. Hale, 2008-Ohio-3426, ¶ 33.

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arrest and was free to leave. She was in the unlocked room alone for approximately

30 minutes before the detectives entered. After being advised of her Miranda rights, Nelson

indicated that she was there voluntarily and agreed to speak with the detectives. Nelson said

that she understood her rights and even indicated that she had been provided her Miranda

rights on a prior occasion. The interview, which lasted for approximately three hours, was

conversational in nature. During that time, Nelson was provided with food and drinks,

permitted to go to the restroom, and allowed to take a break to smoke a cigarette. There are

no claims that the detectives made any false promises of leniency or that they made any

threats that would have caused Nelson to make statements against her will.

{¶ 19} We find no basis for concluding that any actions by the Omaha police

improperly induced Nelson to make any statements during the interview. Thus, we conclude

that the record does not support her claim that her statements were involuntary.

{¶ 20} Nelson’s first and second assignments of error are overruled.

III. Conclusion

{¶ 21} Both of Nelson’s assignments of error being overruled, the judgment of the trial

court is affirmed.

EPLEY, J., and HANSEMAN, J., concur.

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