Therefore, " Miranda does not apply." State v. Dunn , 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24.2. Statements between Summit County Jail and Warren Police Station

An unsolicited and spontaneous statement such as the one made by Neyland in this case is not the product of interrogation, so Miranda does not apply. Rhode Island v. Innis, 446 U.S. 291, 300, 100 S.Ct. 1682, 64 L.Ed.2d 297 (1980) ; State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24. {¶ 120} Second, under the public-safety exception to Miranda established in New York v. Quarles, 467 U.S. 649, 104 S.Ct. 2626, 81 L.Ed.2d 550 (1984), police officers can ask a suspect questions without first giving Miranda warnings if they reasonably believe it is "necessary to secure their own safety or the safety of the public."

The emergency-aid exception allows law enforcement officers to make a warrantless entry into a home or curtilage to render aid if they reasonably believe there is the immediate need for assistance to protect life or prevent serious injury. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 20-22. The emergency aid exception applies where there is an objectively reasonable basis for believing that the subject is in need of immediate aid.

'Numerous state and federal cases have recognized that the Fourth Amendment does not bar police officers from making warrantless entries and searches when they reasonably believe that a person within is in need of immediate aid.'" State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 18, quoting Mincey v. Arizona, 437 U.S. 385, 392, 98 S.Ct. 2408, 57 L.Ed.2d 290 (1978). "The need to protect or preserve life or avoid serious injury is justification for what would be otherwise illegal absent an exigency or emergency." Id., quoting Wayne v. United States, 318 F.2d 205, 212 (D.C.Cir.1963).

Thus, "the requirement that police officers administer Miranda warnings applies only when a suspect is subjected to both custody and interrogation." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24.

However, there are several exceptions to the rule, including the "emergency-aid exception" or the "exigent-circumstance exception." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶13-15. {¶21} "[I]n Michigan v. Fisher, 558 U.S. 45, 130 S.Ct. 546, 175 L.Ed.2d 410 (2009), the [U.S. Supreme C]ourt upheld an officer's warrantless entry into the defendant's residence as reasonable when the police officers who were responding to a call regarding a disturbance observed a tumultuous situation when they arrived at the home, including blood on a damaged vehicle parked in the driveway and witnesses reporting that the defendant was 'going crazy' inside. * * * The Fisher court noted that '[o]fficers do not need ironclad proof of "a likely serious, life-threatening" injury to invoke the emergency aid exception.' * * * Rather, '[a]n action is "reasonable" under the Fourth Amendment, regardless of the individual officer's state of mind, "as long as the circumstances, viewed objectively, justify [the] action.

The requirement that police officers administer Miranda warnings applies when a suspect is subjected to both custody and interrogation. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24. In other words, "Miranda rights only attach when both custody and interrogation coincide."

{¶21} The United States Supreme Court and the Supreme Court of Ohio have recognized a narrower subset of exigent circumstances where law enforcement officers need to respond to emergency situations to protect people from death or serious injury. Brigham City at 403; State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 21. The "emergency-aid" exception allows police to enter a home without a warrant and without probable cause when they reasonably believe, based on specific and articulable facts, that a person within the home is in need of immediate aid.

{¶ 21} The United States Supreme Court and the Supreme Court of Ohio have recognized a narrower subset of exigent circumstances where law enforcement officers need to respond to emergency situations to protect people from death or serious injury. Brigham City at 403, 126 S.Ct. 1943 ; State v. Dunn , 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 21. The "emergency-aid" exception allows police to enter a home without a warrant and without probable cause when they reasonably believe, based on specific and articulable facts, that a person within the home is in need of immediate aid.

"[T]he requirement that police officers administer Miranda warnings applies only when a suspect is subjected to both custody and interrogation." State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 24. In other words, "Miranda rights only attach when both custody and interrogation coincide."