At a Rasmussen hearing on Jedlicka's suppression motions, the district court ruled the written statement admissible and the blood sample inadmissible. At trial on the careless-driving charge, the state presented testimony from both officers who had talked to Jedlicka the night of the accident and from a third officer trained in accident reconstruction. Over objection, Jedlicka's written statement was also admitted into evidence. The jury found Jedlicka guilty of careless driving but not guilty of a companion charge of underage drinking and driving. When the facts are not in dispute, the propriety of a district court's pretrial ruling suppressing evidence is a question of law.
Questions of law receive de novo review.
Jedlicka maintains that her statements on the form were constitutionally inadmissible because a written, rather than oral, warning does not satisfy Miranda requirements. The district court accepted, for purposes of its analysis, that Jedlicka was in custody when she filled out the form. Because it is not specifically contested on review, we proceed on the same assumption. Nonetheless, we find an analysis of the Miranda issue unnecessary because the same evidence was presented through the oral testimony of the police officers. Jedlicka neither moved to suppress those statements nor objected to them during the jury trial.