The Utah Court of Appeals on Aug. 14, 2025, affirmed the conviction of Stephanie Hansen for misdemeanor child abuse, ruling that statements she made on her apartment walkway and later at a police station were admissible because the walkway interview did not constitute custodial interrogation requiring Miranda warnings. Judge Ryan D. Tenney wrote the opinion for a three-judge panel that concurred.

The court ruled the initial interview—on a second-floor open-air walkway where a DCFS caseworker questioned Hansen in the presence of one uniformed officer—did not present “the same inherently coercive pressures” as station-house questioning. That finding defeated Hansen’s motion to suppress the statements she made on the walkway and during a subsequent interview at the police station.

The opinion matters because it clarifies how Miranda custody analysis applies to child-welfare interviews that occur in a semi-public, domestic setting and where police give direct commands about where the interview will occur. The panel acknowledged that officers used forceful language telling Hansen she “had to” go outside, but it concluded the public setting, the presence of passersby and a family member, and the short duration of the encounter weighed against custody for Miranda purposes.

At issue were statements Hansen made after her five-year-old daughter, identified in court documents by the pseudonym Iris, told her she had killed a kitten and said she wanted her mother to die. A DCFS caseworker and two uniformed officers arrived at Hansen’s apartment a few days later. According to recorded bodycam footage and the appellate opinion, Hansen at first suggested the adults speak outside on the walkway and then hesitated at the open doorway. Officer 2 said to Hansen, “You don’t have a choice right now. You need to go outside and talk to them. And I have to be with her.” Officer 1 repeated, “You gotta come outside and talk to this man right here.”

Once on the walkway, the caseworker, who was not a police officer and wore jeans and a polo shirt, questioned Hansen for about thirteen minutes. The caseworker began by saying, “That’s not my goal, okay. I know it looks that way. That’s not my goal,” when addressing Hansen’s fear that DCFS would remove her child. During the conversation Hansen admitted she had “smacked” or “slapped” her daughter and acknowledged leaving a mark on the child’s cheek. The caseworker later observed a mark on the cheek and a bruise on the back of the child’s neck; the child indicated the mother had caused at least some bruising.

A detective later came to the apartment and asked Officer 1 to escort Hansen to the police station. Officer 1 told Hansen, “I’m not arresting you, but I do need to take you to the station so that a detective can talk to you,” but the officer also said she would not be handcuffed if she cooperated. At the station, the detective read Hansen her Miranda warnings verbally. Hansen declined to sign a written waiver but agreed to answer some questions; the station interview was recorded and played at trial.

Hansen argued the walkway interview was custodial because officers told her she had no choice and because the walkway’s banister and positioning of officers limited her movement. The district court denied suppression, finding the walkway was public, not isolated, and that nothing indicated a show of force. The Court of Appeals disagreed with the district court’s initial freedom-to-leave finding: the appellate panel concluded a reasonable person would have felt they were not free to leave given the officers’ command-form language. But on the second step of Miranda custody analysis the appeals panel agreed with the district court that the interview did not present the coercive, station-house environment Miranda protects against, citing the open-air walkway, passing public, the presence of a family member who approached during the interview, the caseworker’s nonuniform appearance and tone, the single silent officer who did not physically restrain Hansen, and the interview’s relatively short duration.

The appeals panel therefore held the officers were not required to give Miranda warnings before the walkway conversation and saw no basis to suppress the later station-house statements, which followed a verbal Miranda advisal. The jury later convicted Hansen of one count of child abuse under Utah Code section 76-5-109(2) and (3)(a); the appellate court affirmed the conviction.

The opinion explains the two-step Miranda custody test used in Utah: (1) whether a reasonable person would have felt free to terminate the interrogation and leave, and (2) if not, whether the environment presented coercive pressures comparable to a station-house interrogation. The court relied on precedent including Howes v. Fields, Berkemer v. McCarty, and Utah appellate decisions such as State v. Fullerton and State v. Goddard in applying those factors.

The case was appealed from the Fourth District Court, Provo Department, No. 201402201. Judge Tenney authored the opinion; Judges David N. Mortensen and John D. Luthy concurred. The opinion was filed Aug. 14, 2025. No further appellate action is noted in the opinion.