Suspect placed in handcuffs for transport to hospital was under custodial arrest absent indicia to the contrary.
Docket Number: 1446835 , Decision Date: November 10, 2014
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An arresting officer’s testimony that he placed a suspect in handcuffs for transport to the hospital by ambulance sufficiently established that the suspect was under custodial arrest. The officer’s subsequent reading of the implied consent notice was therefore proper and timely.