Accordingly, there is no basis to conclude that there was a custodial interrogation. Because there was no custodial interrogation, the trial court did not err by failing to suppress the statements that Mr. Ward made to Ofc. Jackson and Tpr. Ambers.

 

State v. Ward

2023 – Ohio – 328

Second District Appellate Court

Montgomery County, Ohio

February 3, 2023

Two Vehicle Collision

On Tuesday May 11, 2021, a Montgomery County grand jury returned an indictment charging Mr. Antonion Ward with three counts of aggravated vehicular homicide in violation of O.R.C. §2903.06(A)(2)(a), felonies of the second degree. The charges arose from a two-vehicle collision that occurred on July 15, 2020, at the intersection of Olive and Little Richmond Roads in the city of Trotwood.

Mr. Antonion Ward was racing his car, went through a red stop light at Olive and Little Richmond Roads, struck another vehicle and three people died.  Two of Mr. Ward’s passengers and a woman in the other vehicle.  Mr. Ward was convicted of three counts of Aggravated Vehicular Homicide and sentenced to twenty-four to twenty-eight years in prison.

Triple Fatality

The indictment alleged that Mr. Ward had been operating one of the vehicles involved in the collision and that, in doing so, he recklessly caused the deaths of his passengers, Michael Stephens and Elgin Wilson IV, and of the driver of the other vehicle in the collision, Ms. Leah Smith. Mr. Ward pled not guilty to the indicted charges and thereafter filed a motion to suppress. In the motion, Mr. Ward sought to suppress statements that he had made to investigating officers during two separate interviews on grounds that the officers did not advise him of his Miranda rights before questioning him.

Motion to Suppress is Denied

On March 7, 2022, the trial court held a hearing on Mr. Ward’s motion to suppress. At the hearing, the State presented testimony from the officers who had questioned Mr. Ward. The first officer, Trooper Joshua Jones of the State Highway Patrol, testified that he had interviewed Mr. Ward on the night of the accident while Mr. Ward was at the hospital receiving medical treatment for his injuries. The second officer, Officer Sherri Jackson of the Trotwood Police Department, testified that she and another officer, Trooper Ambers, had interviewed Mr. Ward at his residence two weeks after the accident. Both Tpr. Jones and Ofc. Jackson testified that, at the time of their respective interviews, Mr. Ward had not been a criminal suspect, had not been placed under arrest, and had not been advised of his Miranda rights before questioning. The officers’ testimony also established that the officers had in no way restrained Mr. Ward’s freedom of movement or his ability to terminate the interviews.

After considering the officers’ testimony and the exhibits, which included a written statement of the questions and answers given during Tpr. Jones’ interview and an audio recording of Ofc. Jackson’s interview, the trial court determined that neither interview had qualified as a custodial interrogation that required Miranda warnings. Accordingly, the trial court overruled Mr. Ward’s motion to suppress the statements that he had made to each of the officers.

Trial

Following the trial court’s ruling on Mr. Ward’s motion to suppress, the matter proceeded to a three-day jury trial in May 2022. During trial, the State presented testimony from multiple witnesses who had observed the traffic accident. The State also presented testimony from the fire and law enforcement officers who had responded to the scene of the accident and investigated the matter. In addition, the State presented testimony from the coroner who had performed autopsies on the three victims and from an expert traffic accident reconstructionist. Mr. Ward also testified in his defense.

A Race to Three Deaths

The trial testimony established that on the evening of Wednesday July 15, 2020, Mr. Ward, who was then 19 years old, drove his mother’s Chevy Cruz to pick up his 18-year-old stepbrother, Michael Stephens, and his 18-year-old friend, Elgin Wilson, from a pool party. Mr. Ward’s plan was to drive Stephens and Wilson to an after-party located at an Airbnb rental house. While traveling to the after-party, Mr. Ward stopped his vehicle at a traffic light on Olive Road near the Trotwood police station. An SUV driven by Mr. Ward’s 17-year-old friend, E’Mariha Combs, was stopped beside Mr. Ward in the adjacent lane of traffic. Ms. Combs had also been at the pool party and was driving a group of her friends and her 14-year-old brother, Emerson, to the same after-party that Mr. Ward and his friends were traveling to attend. Mr. Ward and Ms. Combs saw each other as they were sitting side-by-side at the traffic light, and they both took off fast on Olive Road once the light turned green.

Ms. Combs testified that, when she took off from the traffic light, she drove 80 miles per hour down Olive Road. Ms. Combs testified that Mr. Ward kept up with her speed and eventually positioned his vehicle behind her once Olive Road went from two lanes to one. During that time, Ms. Combs testified that she and Mr. Ward passed two or three vehicles on Olive Road by weaving in and out of the oncoming traffic lane. Ms. Combs claimed that, when she approached an intersection with Little Richmond Road, she drove into a turn lane and stopped her vehicle at a traffic light that was positioned at the intersection. Ms. Combs testified that Mr. Ward then passed her and went straight through the intersection while the traffic light was red. Ms. Combs testified that Mr. Ward traveled through the intersection at approximately 75 miles per hour without braking. Thereafter, Ms. Combs saw Mr. Ward’s vehicle collide with a vehicle traveling on Little Richmond Road; Mr. Ward’s vehicle flew into the air, touched a power line, caught fire, and landed in a nearby wooded area, while the other vehicle flipped over and landed in a ditch off the road.

The car that is on fire ran a red light

Ms. Combs’ brother, Emerson, who had been in the SUV with Ms. Combs, testified to seeing Mr. Ward, Stephens, and Wilson stopped next to them at a traffic light by the Trotwood police station. After that, Emerson testified that Ms. Combs started to drive fast down Olive Road, which he noted had a speed limit of 35 miles per hour. Emerson testified that he told Ms. Combs to slow down and that Ms. Combs thereafter drove into a turn lane and stopped their vehicle at a red light at the intersection of Little Richmond Road. Emerson testified that he saw Mr. Ward’s vehicle pass them on the driver’s side and then collide with another vehicle traveling on Little Richmond Road. Emerson called 9-1-1 to report the accident. An audio-recording of Emerson’s 9-1-1 call was played for the jury and admitted into evidence as State’s Exhibit 66. During the call, Emerson can be heard telling the operator that: “The car that is on fire ran a red light.”

I know he passed me probably going about a good 100 miles per hour

Another motorist, Ms. Karrie Canady, testified that on the day of the accident, she was driving 40 miles per hour on Olive Road when an SUV and another vehicle following the SUV came up quickly behind her and passed her by driving into the oncoming traffic lane. Ms. Canady testified that both vehicles were traveling at the same rate of speed, which she estimated was approximately 65 to 70 miles per hour. Ms. Canady testified that the SUV took a wide right turn onto Little Richmond Road while the other vehicle behind it went straight through the intersection after the traffic light had turned red. The next thing Ms. Canady remembered was seeing smoke and hearing a collision. Ms. Canady called 9-1-1 and reported the accident; an audio recording of Ms. Canady’s 9-1-1 call was played for the jury and admitted into evidence as State’s Exhibit 67. During the call, Ms. Canady can be heard saying: “There’s been a really really bad car accident on Little Richmond and it’s on fire. It’s in the woods. I know he passed me probably going about a good 100 miles per hour.” During the call, Ms. Canady also advised the 9-1-1 operator that there was a baby in one of the vehicles.

It’s my fault; I should have told him no.

Kimberly Moore, a resident who lived near the intersection of Olive and Little Richmond Roads, testified that on the day of the accident, she was walking her dog when she heard a loud explosion and saw a vehicle flying into pieces. Ms. Moore testified that the vehicle was so high in the air that she could see it over the top her next-door neighbor’s roof. Ms. Moore testified that she did not recall hearing any brakes or screeching of tires. Ms. Moore testified that she immediately called 9-1-1 while her boyfriend ran to Mr. Ward the front of their driveway. Ms. Moore testified that when her boyfriend came back, he told her that there was a baby in one of the vehicles. Ms. Moore also testified to seeing a young woman jump out of an SUV and pace up and down the street while frantically screaming: “It’s my fault; I should have told him no.”

Lt. Snyder observed two victims inside the vehicle who were charred beyond recognition

Lieutenant Michael Snyder of the Trotwood Fire Department was the first officer to arrive at the scene of the accident. Lt. Snyder testified that when he arrived, he saw a vehicle off to the left of the road on its side against a pole and another vehicle in the woods fully engulfed in flames. Lt. Snyder testified that he and another officer made their way into the woods and extinguished the flames coming from the vehicle that was on fire. After doing so, Lt. Snyder observed two victims inside the vehicle who were charred beyond recognition. Snyder testified that a third person, Mr. Ward, was found approximately 20 yards from the vehicle and that Mr. Ward had a broken leg.

The Youngest and Smallest Among the Victims Survived

Continuing, Lt. Snyder testified that he observed a female lying halfway out of the other vehicle and that she showed no signs of life. Lt. Snyder testified that he became concerned upon observing a child safety seat in the female’s vehicle. However, shortly after observing the safety seat, Lt. Snyder saw a bystander walking with the child who had been in the vehicle. Lt. Snyder testified that the child was given to a medic and taken to Dayton Children’s Hospital. In addition, Lt. Snyder identified photos of the accident scene, which were taken by Trooper Alexander Davis of the State Highway Patrol. Tpr. Davis testified at trial and confirmed that he had taken the photographs in question and that he had helped prepare a basic field sketch of the accident scene.

[C]ause of death was a fracture to the base of her skull, which severed her brainstem

Coroner Lee Lehman testified to performing autopsies on the three victims who died in the accident. Coroner Lehman testified that Ms. Leah Smith had several broken bones and internal injuries and that her cause of death was a fracture to the base of her skull, which severed her brainstem. Coroner Lehman testified that Stephens had a ruptured liver and that his cause of death was a torn aorta of the heart. Coroner Lehman testified that Wilson had fractures in his femur and spine, liver lacerations, and a fatal head trauma that caused bleeding over the surface of his brain. Coroner Lehman further testified that the victims’ injuries were consistent with a highway-speed collision.

Singing, Dancing and Having Fun Defense

Officer Sherri Jackson, who had also testified at the suppression hearing, confirmed that the speed limit on Olive Road was 35 miles per hour and 45 miles per hour on Little Richmond Road. Ofc. Jackson also testified regarding her interview with Mr. Ward on July 29, 2020, at his residence. An audio-recording of the interview was played for the jury and admitted into evidence as State’s Exhibit 68(A). On the recording, Mr. Ward said that the traffic light at the intersection in question went from green to yellow as he approached, and that the light was yellow as he went through the intersection. Mr. Ward also told Ofc. Jackson that he had never driven in the oncoming traffic lane, had not been speeding when he went through the intersection, and had not seen the other vehicle coming from Little Richmond Road. Mr. Ward also indicated that he, Stephens, and Wilson had been singing, dancing, and having fun in the vehicle immediately before the accident.

Mr. Ward had been traveling within a range of 70.02 to 78.96 miles per hour

Trooper Jaysen Kelly of the State Highway Patrol, an expert traffic accident reconstructionist who prepared a crash reconstruction report on the accident in question, testified that he had used a piece of survey equipment known as a Trimble Total Station to create profiles of the accident scene and the vehicles. According to Tpr. Kelly, those profiles helped him determine the vehicles’ “crush damage.” Tpr. Kelly also testified that his calculations established that, at the time of the accident, Mr. Ward had been traveling within a range of 70.02 to 78.96 miles per hour, and that Leah Smith had been traveling within in a range of 40.5 to 45.6 miles per hour.  Tpr. Kelly also testified that, even without using any mathematical or scientific calculations, his experience and common sense led him to believe that the accident involved a high rate of speed.

Mr. Ward also stipulated to the fact that his learner’s permit for driving had been suspended and that he had had no driving privileges at the time of the accident.

Mr. Ward testified that he accepted the accuracy of the speeds testified to by Tpr. Kelly and thus admitted to speeding during the accident. Mr. Ward testified that he had told Ofc. Jackson that he was not speeding during his interview with her because he had been in denial. Mr. Ward also stipulated to the fact that his learner’s permit for driving had been suspended and that he had had no driving privileges at the time of the accident. Regarding the accident, Mr. Ward testified that he had passed Ms. Combs on Olive Road while she slowed down and turned right onto Little Richmond Road. Mr. Ward claimed that Stephens had told him to go straight through the Olive and Little Richmond intersection and that he did not remember anything else from that point on.

Mr. Ward … claimed that those dangers had slipped his mind

On cross-examination, Mr. Ward acknowledged that traffic laws require motorists to follow the speed limit, stop at red lights, and stay in the correct lane of travel. Mr. Ward also acknowledged that failing to follow those traffic laws could result in an accident and people getting injured or killed. Mr. Ward, however, claimed that those dangers had slipped his mind and that he had not thought he was putting himself or others in danger because he had looked both ways and had not seen the other vehicle coming.

Guilty … and a mandatory minimum term of 24 years in prison to a maximum term of 28 years in prison

After considering the foregoing testimony and exhibits, the jury found Mr. Ward guilty on all three counts of aggravated vehicular homicide. Pursuant to the Reagan Tokes Act, the trial court ordered Mr. Ward to serve an aggregate, mandatory minimum term of 24 years in prison to a maximum term of 28 years in prison. The trial court also ordered Mr. Ward to pay restitution and suspended his driving privileges for life.

Four Feeble Appeals

Mr. Ward appeals from his conviction, raising four assignments of error for review. For purposes of clarity, we will address Mr. Ward’s assignments of error out of order.

Miranda Violation Appeal

Under his second assignment of error, Mr. Ward contends that the trial court erred by failing to grant his motion to suppress the statements he made during his interviews with Tpr. Jones and Ofc. Jackson. Mr. Ward contends that his statements to the officers should have been suppressed because the officers had not advised him of his Miranda rights before questioning him.

Established Case Law

Miranda

In Miranda v. Arizona, 384 U.S. 436 (1966), the United States Supreme Court adopted procedural safeguards to secure the Fifth Amendment’s constitutional guarantee against self-incrimination.

“Police, however, are not required to administer Miranda warnings to every person they question, even if the person being questioned is a suspect.” Oregon v. Mathiason, 429 U.S. 492, 495 (1977)

What is Custody?

“Determining whether questioning is ‘a custodial interrogation requiring Miranda warnings demands a fact-specific inquiry that asks whether a reasonable person in the suspect’s position would have understood himself or herself to be in custody while being questioned.'” Cleveland v. Oles, 152 152 Ohio St.3d 1 (2017)

“‘The factors a court should consider in applying this reasonable person test include whether the encounter takes place in surroundings that are familiar to the suspect; the number of law enforcement officers present, as well as their conduct and demeanor; the degree of physical restraint imposed; and the duration and character of the interrogation.'” State v. Magnone, 2016 – Ohio – 7100

Other factors that may be considered are: 1) the location where the questioning took place; 2) whether the defendant was a suspect when the interview began; 3) any restrictions on the defendant’s freedom to leave; 4) whether the defendant was handcuffed or was told he was under arrest; 5) whether threats were made during the interrogation; 6) whether the defendant was physically intimidated during the interrogation; 7) whether the police verbally dominated the interrogation; 8) the defendant’s purpose for being at the location of the questioning; 9) whether neutral parties were present at any point during the questioning; and 10) whether police took any action to overpower, trick, or coerce the defendant into making a statement.  State v. Estepp,1997 Ohio App. LEXIS 5279

Interview at Hospital with Tpr. Jones

Mr. Ward asserts that his interview with Tpr. Jones at the hospital amounted to a custodial interrogation and that Tpr. Jones’ undisputed failure to give Miranda warnings before the interview rendered the statements he made during the interview inadmissible. Mr. Ward claims that the interview with Tpr. Jones amounted to a custodial interrogation because Tpr. Jones “summoned” him for questioning while he was lying in a hospital bed. According to Mr. Ward, his injury, a broken leg, restricted his freedom of movement and prevented him from having the ability to leave the interview. Mr. Ward further claims that he was physically intimidated by Tpr. Jones, who was armed and in uniform while standing over his bed questioning him. Mr. Ward claims that all these factors would have led a reasonable person in his position to believe that he had been in custody during the interview. We disagree.

Established Case Law for Hospital Interviews

“Ohio courts have found police questioning of individuals in the hospital, at times, to be custodial in nature.”State v. Smith, 1996 Ohio App. LEXIS 1851.  This court, however, has recognized that, unlike a police station, a hospital is “a place an individual would normally feel free to leave.” State v. Estepp, 1997 Ohio App. LEXIS 5279

This court has also recognized that confinement in a hospital bed does not necessarily “‘[A]mount to a coercive environment or rise to the degree or level of restraint on freedom of movement generally associated with a formal arrest.'” State v. Smith, 1996 Ohio App. LEXIS 1851

In State v. Pyle, 2003 – Ohio – 6664, this court found no custodial interrogation under circumstances where an investigating officer interviewed the defendant in a hospital room while the defendant was strapped to a backboard and wearing a neck brace.  We reached this conclusion because the defendant “was not brought to the hospital by [the investigating officer] for questioning, but was brought by medics for treatment of his injuries.”  Because the defendant was not restrained by the investigating officer, “but was restrained for medical treatment due to his injuries” we found that there was “nothing in the record to indicate that [the defendant] was not free to leave the room due to [the investigating officer], or that [the investigating officer] did anything to prevent [the defendant] from leaving the room.”

Mr. Ward Could Have Left the Hospital Ward

The present case is analogous to Pyle, as Mr. Ward was taken to the hospital by medics for purposes of receiving medical treatment for his broken leg and other injuries, not for police questioning. Moreover, there is nothing in the record indicating that Tpr. Jones did anything to restrict Mr. Ward’s freedom of movement while questioning him at the hospital. Simply because Mr. Ward was confined to a hospital bed and unable to freely move about due to his injuries does not mean that he was in custody for purposes of Miranda. State v. Smith, 1996 Ohio App. LEXIS 1851

Mr. Ward was Not Summoned

Furthermore, Mr. Ward’s claim that Tpr. Jones “summoned” him for questioning is unsupported by the record. While no specific finding was made by the trial court on this matter, the record of the suppression hearing establishes that Tpr. Jones asked hospital staff to take him to Mr. Ward’s hospital room, where Tpr. Jones then introduced himself to Mr. Ward and explained his reason for being there, i.e., to ask questions about the traffic accident.  Nothing in the record indicates that Mr. Ward was brought to Tpr. Jones for questioning. Instead, the record establishes that Tpr. Jones sought out Mr. Ward with the help of hospital staff, which is similar to the circumstances in Pyle.

An Armed Uniformed Police Officer is Not Intimidating

In addition, Mr. Ward’s claim that Tpr. Jones was physically intimidating during the interview is unpersuasive. As previously discussed, this claim is based merely on the fact that Tpr. Jones was armed and in uniform while standing over Mr. Ward’s bed to question him. Because Mr. Ward was confined to his bed and because officers like Tpr. Jones typically wear uniforms and carry weapons while on duty, we do not find that those attributes would have caused a reasonable person in Mr. Ward’s position to believe that he was in custody. This is especially true since the trial court found that Tpr. Jones never drew his weapon during the interview and never told Mr. Ward that he was under arrest.

He that keepeth his mouth keepeth his life: but he that openeth wide his lips shall have destruction.

Proverbs 13:3

The trial court also found that the interview with Tpr. Jones lasted only ten or fifteen minutes and that Tpr. Jones wrote down all the questions and answers from the interview. The written questions and answers were admitted into evidence during the suppression hearing, and they established that the interview was restricted to 11 straight forward questions pertaining to the accident, the occupants in Mr. Ward’s vehicle, and whether Mr. Ward had been under the influence of drugs or alcohol.  Accordingly, there is nothing in the record indicating that Tpr. Jones threatened or coerced Jones during the interview. In fact, the trial court found that Tpr. Jones did not even know if Mr. Ward was a criminal suspect at the time of the interview and that Mr. Ward was free to terminate the interview.

Upon review, we find that the trial court’s findings were supported by competent, credible evidence in the record. Based on those findings, we cannot say that a reasonable person in Mr. Ward’s position would have felt that he was in custody at the time he was questioned by Tpr. Jones. Accordingly, there was no custodial interrogation for which Tpr. Jones was required to give Miranda warnings. Because there was no custodial interrogation, the trial court did not err by failing to suppress the statements that Mr. Ward made to Tpr. Jones at the hospital.

Interview at Mr. Ward’s Residence with Ofc. Jackson and Tpr. Ambers

Mr. Ward also asserts that his interview with Ofc. Jackson and Tpr. Ambers at his residence amounted to a custodial interrogation for which Miranda warnings were required. We again disagree.

Established Case Law on Custodial Interrogation

“In general, questioning by law enforcement officers is less likely to rise to the level of a custodial interrogation when it occurs in a defendant’s home.” State v. Martinez, 2016 – Ohio – 5515

However, “Ohio courts have found that the ‘inherently coercive’ atmosphere of a custodial interrogation can occur even if a suspect is questioned in his home if he is thereby ‘deprived of his freedom of action in a significant way.'” State v. Sevrence, 1997 Ohio App. LEXIS 652 quoting Orozco v. Texas, 394 U.S. 324 (1969)

Custody means … Custody

In this case, the trial court found that Mr. Ward’s interview with Ofc. Jackson and Tpr. Ambers took place at Mr. Ward’s residence. The trial court also found that Mr. Ward’s younger brother answered the door and let the officers inside the residence after Mr. Ward invited the officers to talk with him inside his bedroom. Based on the audio-recorded interview, the trial court additionally found that the interview lasted approximately twenty minutes and was conversational in nature. The trial court further found that Mr. Ward was coherent, upbeat, and happy during the interview. In addition, the trial court found that Mr. Ward never asked to end the interview, was not placed under arrest or detained, and the officers did not make any promises or threaten Mr. Ward.

Mr. Ward’s Interviews were Consensual and therefore Admissible

Upon review, we find that all the trial court’s findings were supported by competent, credible evidence in the record. Based on those findings, we cannot say that Mr. Ward was in custody or that he was deprived of his freedom in any significant way during the interview at his residence. In so holding, we note that Mr. Ward’s freedom of movement was restricted only by his broken leg, not by the officers. The officers never confined Mr. Ward or prevented him from moving about while they were questioning him.

Conclusion and Holding

For the foregoing reasons, we cannot say that a reasonable person in Mr. Ward’s position would have believed that he was in custody during the interview at his residence. Accordingly, there is no basis to conclude that there was a custodial interrogation. Because there was no custodial interrogation, the trial court did not err by failing to suppress the statements that Mr. Ward made to Ofc. Jackson and Tpr. Ambers at his residence.

Mr. Ward’s second assignment of error is overruled.

There were three additional appeals that are not reviewed in this article.  All the appeals were denied by the court.  As of May 2024, Mr. Ward is serving his 24–28-year sentence at the Madison Correctional Institute in Madison County, Ohio.

Information for this article was obtained from State v. Ward, 2023 – Ohio – 328.

Mr. Ward Ohio Department of Corrections and Rehabilitation link: https://appgateway.drc.ohio.gov/OffenderSearch/Search/Details/A799677

State v. Ward, 2023 – Ohio – 328 was issued by the Second District Appellate Court on February 3, 2024, and is binding in the following Ohio Counties: Champaign, Clark, Darke, Greene, Miami and Montgomery.

Lessons Learned:

  1. What is the Two-Part Miranda Test? On Monday June 13, 1966, the U.S. Supreme Court overturned Mr. Miranda’s conviction concluding law enforcement MUST provide the following ‘rights’ to the suspect if s/he is in custodyAND s/he is subjected to interrogation.  In this case Mr. Ward claimed he was in custody at both the hospital and later at his home.  The trial court and the Second District Appellate Court were in agreement that Mr. Ward was not in custody for purposes of Miranda.
  2. What is Miranda Custody? For Miranda to ‘attach’ or be required a suspect must first be in custody and second be interrogated. “Custody” is when a defendant is taken into custody “[O]r otherwise deprived of his freedom by the authorities in any significant way and is subjected to questioning.” Miranda v. Arizona, 384 U.S. 436, 478 (1966).
  3. Is a suspect on a backboard in an emergency room ‘in Miranda Custody’? – Law enforcement must also be cognizant of whether someone in a hospital strapped to a backboard is in custody for purpose of Miranda. The Second District Appellate previously evaluated this situation in State v. Pyle, 2003 – Ohio – 6664.   The court found no custodial interrogation under circumstances where an investigating officer interviewed the defendant in a hospital room while the defendant was strapped to a backboard and wearing a neck brace. The Second District Appellate Court reached this conclusion because the defendant “was not brought to the hospital by [the investigating officer] for questioning, but was brought by medics for treatment of his injuries.”
  4. Pre-Sent Arms! Ohio State Highway Patrol Trooper Joshua Jones and Trotwood Police Officer Sherri Jackson should both be highly commended for their legal tactics in interviewing Mr. Ward. Well done!

Does your agency train on Custodial Interrogation?

Don’t fail your training.

Don’t let your training fail you!

Be safe, smart and objectively reasonable!

Robert H. Meader Esq.