A woman voluntarily interviewed with police detectives while other officers executed a search warrant at her home. Upon learning of this at the end of the interview, two detectives were unsure if they should let her go. The woman contends that these factors together rendered the interview a custodial interrogation without Miranda warnings thus making her statements inadmissible. A court would likely find, however, that the woman was never in custody because she was never under formal arrest or an equivalent to formal arrest.
The Supreme Court has defined “custody” with respect to custodial interrogations as a “‘formal arrest or restraint on freedom of movement’ of the degree associated with a formal arrest.” California v. Beheler, 463 U.S. …show more content…
For example, an interrogation at a police station is highly relevant to finding custody, but not dispositive. See id. at 262. Furthermore, whether someone is a suspect or witness relevant only if officers expressly communicate this to the person questioned. Stansbury v. California, 511 U.S. 318, 324 (1994). The Supreme Court explained that the subjective views of neither the officer nor the person questioned are relevant for determining custody. Id. at 323. What ultimately matters is how knowledge of being a suspect affects your understanding of the ability to end the interrogation and leave. Id. at 325.
Linking the facts of the case with the custody factors is straightforward. In this case the woman voluntarily went to the police station to interview with two detectives for over an hour. There are not enough facts given to know the interaction between the woman and the detectives during the interview. Also, there was no indication she was either physically restrained with handcuffs nor told expressly she could not leave. In addition, the detectives never told her she was a suspect and after the interview concluded, detained her briefly upon learning about the search warrant instead of immediately letting her
The Supreme Court has defined “custody” with respect to custodial interrogations as a “‘formal arrest or restraint on freedom of movement’ of the degree associated with a formal arrest.” California v. Beheler, 463 U.S. …show more content…
For example, an interrogation at a police station is highly relevant to finding custody, but not dispositive. See id. at 262. Furthermore, whether someone is a suspect or witness relevant only if officers expressly communicate this to the person questioned. Stansbury v. California, 511 U.S. 318, 324 (1994). The Supreme Court explained that the subjective views of neither the officer nor the person questioned are relevant for determining custody. Id. at 323. What ultimately matters is how knowledge of being a suspect affects your understanding of the ability to end the interrogation and leave. Id. at 325.
Linking the facts of the case with the custody factors is straightforward. In this case the woman voluntarily went to the police station to interview with two detectives for over an hour. There are not enough facts given to know the interaction between the woman and the detectives during the interview. Also, there was no indication she was either physically restrained with handcuffs nor told expressly she could not leave. In addition, the detectives never told her she was a suspect and after the interview concluded, detained her briefly upon learning about the search warrant instead of immediately letting her