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Background

A house in the town of Salem, Polk County (most of Salem is located in Marion County), Oregon was burglarized. A witness to the burglary contacted the local sheriff's office and implicated an 18 year old neighbor, Michael Elstad. Two officers went to Elstad's home with a warrant for his arrest. When the police entered the house and asked Elstad about the burglary he admitted to the burglary. The officers then escorted Elstad to the sheriff's headquarters. About an hour later, the same officers began interrogating Elstad by reading him his Miranda rights for the first time. During this interrogation, the officers obtained a written admission of Elstad's involvement in the burglary. Subsequently, Elstad was convicted of burglary and sentenced to 5 years and $18,000 in restitution.