UT: Officer’s testimony about consent was hearsay but not inadmissible or excludable

The officer’s description of consent to search a truck driven by another was not inadmissible hearsay. The effort to show that it was unreliable was insufficient, and it was not so unreliable to be excludable. State v. Clark, 2015 UT App 289, 2015 Utah App. LEXIS 306 (Nov. 27, 2015).

Defendant was not “in custody” for Miranda purposes when the persons with “custody” were private actors at a department store. Paige v. State, 2015 Md. App. LEXIS 165 (Nov. 30, 2015).*