The investigator then asked Underwood where the child was because he was concerned about her safety, Dicksen argued.
Luker said the investigator, after seeing the shirt, must have known the body was hidden in the trunk and should have stopped and read Underwood his rights before asking about Bolin's whereabouts.
"He just saw the girl's shirt, which prompted a question about where she might be. Not for one second did he think she was in the trunk," Dicksen said.
Luker also asked appeals judges to rule that incriminating statements Underwood made while waiting to be formally questioned in Bolin's death were made under duress.
Underwood was sitting in an outer office waiting to be interrogated when he "spontaneously started talking," Dicksen said. "He initiated the conversation. He was not coerced."
The appeals judges gave attorneys 15 days in which to submit case law in support of their arguments.
Jennifer Fox, Jamie's mother, said the hearing was upsetting because she heard details about her daughter's death that she hadn't known.
Her family shielded her during the trial, Rose Fox said, "so some of the things they talked about today she was hearing for the first time."
Jamie Bolin was named after her grandmother and also after her grandfather James, Rose Fox said.
"She was a treasured member of our family. We don't want her forgotten," the grandmother said.