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."

o firefighters); Trejo v. State , 76 So.3d 684, 689 (Miss. 2011) (under facts of case, vehicle stop not justified under public servant exception); State v. Graham , 175 P.3d at 890 (Montana) (seizure not justified under public safety exception); State v. Bakewell , 273 Neb. 372, 730 N.W.2d 335, 338 (2007) (vehicle stop justified under public servant exception); State v. Rincon , 122 Nev. 1170, 147 P.3d 233, 237 (2006) (recognizing community caretaking exception); State v. Boutin , 161 N.H. 139, 13 A.3d 334, 337–38 (2010) (under facts of case, seizure not justified under public servant exception); State v. Vargas , 213 N.J. 301, 63 A.3d 175, 177 (2013) (warrantless entry into defendant's apartment not justified by emergency aid exception); Ryon , 108 P.3d at 1041 (New Mexico) (holding warrantless entry into defendant's home not justified under emergency aid exception); State v. Smathers , 232 N.C.App. 120, 753 S.E.2d 380, 382 (2014) (formally recognizing community caretaking doctrine); State v. Dunn , 131 Ohio St.3d 325, 964 N.E.2d 1037, 1042 (Ohio 2012) (seizure of individual justified under emergency aid exception); State v. Kleven , 887 N.W.2d 740, 743 (S.D. 2016) (seizure justified under public servant exception); State v. McCormick , 494 S.W.3d 673, 686 (Tenn. 2016) (seizure justified under public servant exception); Hernandez v. State , 376 S.W.3d 863, 877 (Tex. Ct. App. 2012) (seizure not justified under public servant exception); Anderson , 362 P.3d at 1240 (Utah) (holding seizure justified under public servant exception); State v. Hinton , 198 Vt. 167, 112 A.3d 770, 773 (2014) (seizure justified under public servant exception); Knight v. Commonwealth , 61 Va.App. 297, 734 S.E.2d 716, 721 (2012) (community caretaking doctrine did not justify police officer's search of defendant's backpack); Acrey , 64 P.3d at 603 (Washington) (holding detention of juvenile justified under community caretaking doctrine); Ullom v. Miller , 227 W.Va. 1, 705 S.E.2d 111, 121 (2010) (seizure justified under public safety exception); State v. Kramer

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

hereby adopt the community caretaking exception to the Fourth Amendment.”); State v. Rincon, 122 Nev. 1170, 147 P.3d 233, 237 (2006) (adopting the community caretaking exception to the Fourth Amendment); State v. Boutin, 161 N.H. 139, 13 A.3d 334, 337–38 (2010) (discussing prior New Hampshire cases applying the community caretaking exception); State v. Edmonds, 211 N.J. 117, 47 A.3d 737, 752 (2012) (“The community-caretaking doctrine is an exception to the warrant requirement....”); State v. Ryon, 137 N.M. 174, 108 P.3d 1032, 1041 (2005) (acknowledging that its earlier description of community caretaking as a form of consensual encounter “was wrong” and cautioning that certain prior decisions should “not be viewed as limiting the community caretaker exception to voluntary or consensual police-citizen encounters”); State v. Smathers, 232 N.C.App. 120, 753 S.E.2d 380, 384 (2014) (recognizing the community caretaking doctrine as an exception to the Fourth Amendment warrant requirement); State v. Dunn, 131 Ohio St.3d 325, 964 N.E.2d 1037, 1042 (2012) (recognizing “the community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement”); Coffia v. State, 191 P.3d 594, 597–98 (Okla.Crim.App.2008) (discussing the community caretaking exception to the Fourth Amendment); State v. Wood, 210 Or.App. 126, 149 P.3d 1265, 1267–68 (2006) (describing an Oregon statute as a community caretaking exception to the warrant requirement); State v. Deneui, 775 N.W.2d 221, 235 (S.D.2009) (recognizing and applying the community caretaking exception); Wright v. State, 7 S.W.3d 148, 151–52 (Tex.Crim.App.1999) (en banc) (describing Cady as recognizing “a community caretaking function of law enforcement as a reasonable exception to the Fourth Amendment's warrant requirement” and acknowledging “the existence of the community caretaking function in Texas”); Provo City v. Warden, 844 P.2d 360, 363–65 (Utah Ct.App.1992) (upholding a “seizure” as reasonable under the Fourth Amendment based on the community caretaking doctrine); State v. Fo

Ohio courts also recognize that the community-caretaker exception to the Fourth Amendment's warrant requirement may justify seizure of a person. E.g., State v. Dunn, 131 Ohio St.3d 325, 964 N.E.2d 1037, 2012–Ohio–1008 (2012) (applying exception to police seizure of suicidal man); State v. Engle, No. 25226, 2013–Ohio–1818, 2013 WL 1870544 (Ohio Ct.App. May 3, 2013) (community-caretaking function justified seizure of injured, bleeding man to determine need for immediate medical attention). Furthermore, in United States v. Garner, 416 F.3d 1208 (10th Cir.2005), a police officer responded to reports of a man seen unconscious and slumped over.

eb. 372, 730 N.W.2d 335, 338 (2007) (“[W]e hereby adopt the community caretaking exception to the Fourth Amendment.”); State v. Rincon, 122 Nev. 1170, 147 P.3d 233, 237 (2006) (adopting the community caretaking exception to the Fourth Amendment); State v. Boutin, 161 N.H. 139, 13 A.3d 334, 337 (2010) (discussing prior New Hampshire cases applying the community caretaking exception); State v. Edmonds, 211 N.J. 117, 47 A.3d 737, 752 (2012) (“The community-caretaking doctrine is an exception to the warrant requirement, not a roving commission to conduct a nonconsensual search of a home in the absence of exigent circumstances.”); Ryon, 2005–NMSC–005, ¶ 20, 108 P.3d at 1041 (acknowledging that its earlier description of community caretaking as a form of consensual encounter “was wrong” and cautioning that certain prior decisions should “not be viewed as limiting the community caretaker exception to voluntary or consensual police-citizen encounters”); State v. Dunn, 2012–Ohio–1008, at ¶ 22, 131 Ohio St.3d 325, 964 N.E.2d 1037, 1042 (2012) (“Thus, we hold that the community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement allows police officers to stop a person to render aid if they reasonably believe that there is an immediate need for their assistance to protect life or prevent serious injury.”); Coffia v. State, 2008 OK CR 24, ¶¶ 10–13, 191 P.3d 594, 597–98 (2008) (discussing the community caretaking exception to the Fourth Amendment); State v. Wood, 149 P.3d 1265, 1267–68 (Or.Ct.App.2006) (describing an Oregon statute as a community caretaking exception to the warrant requirement); State v. Deneui, 2009 SD 99, ¶ 33, 775 N.W.2d 221, 235 (2009) (“The community caretaker exception has been recognized only in the context of automobiles by the United States Supreme Court.” (citing Cady v. Dombrowski, 413 U.S. 433, 441, 93 S.Ct. 2523, 37 L.Ed.2d 706 (1973)));

State courts have permitted police officers to justify vehicular stops based on the emergency-aid exception. See State v. Dunn , 131 Ohio St.3d 325, 964 N.E.2d 1037, 1042 (2012) ; State v. Stapa , 46 So.3d 264, 266 (La. App. 2 Cir. 2010).See, e.g. , United States v. Collins , 321 F.3d 691, 694–95 (8th Cir. 2003) (permitting officer to lean into parked car because he had reasonable belief that persons were injured); United States v. Kelly , 267 F.Supp.2d 5, 9 (D.D.C. 2003) (no Fourth Amendment violation where officers entered car to treat visible crash victim).

“[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.”

{¶ 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.

{¶ 20} Another subset of the exigent-circumstances category is the emergency-aid exception. Courts recognize a community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement is necessary to allow police to respond to emergency situations where life or limb is in jeopardy. State v. Dunn, 131 Ohio St.3d 325, 2012-Ohio-1008, 964 N.E.2d 1037, ¶ 21. In dealing with this exception, “[t]he key issue is whether the officers ‘had reasonable grounds to believe that some kind of emergency existed * * *. The officer must be able to point to specific and articulable facts, which, taken with rational inferences from those facts, reasonably warrant intrusion into protected areas.’ ”