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Stansbury v. California

Supreme Court of the United States · 1994 · Criminal Procedure

Criminal ProcedureMiranda custodycustodial interrogationMirandacustodycustodial interrogationobjective testreasonable person

Facts

Police investigating a child's rape and murder asked Stansbury to come to the station as a possible witness, and he agreed and rode there in the front seat of a police car. At the station, Lieutenant Johnston questioned him without Miranda warnings about his activities on the day of the crime. During the interview, Stansbury said he had driven a turquoise car that night and admitted prior convictions for rape, kidnaping, and child molestation; Johnston then stopped the interview, another officer gave Miranda warnings, Stansbury invoked counsel, and he was arrested. The trial court and California Supreme Court treated the point at which police suspicion focused on Stansbury as central to whether he was in custody before warnings were given.

Issue

In deciding whether a person questioned by police is in custody for Miranda purposes, may a court rely on the interrogating officer's subjective and undisclosed belief about whether that person is or is not a suspect? More specifically, did the California Supreme Court err by treating investigative focus on Stansbury as a key consideration in the custody analysis?

Rule

Miranda warnings are required only when there is a formal arrest or a restraint on freedom of movement of the degree associated with formal arrest. The custody determination depends on the objective circumstances of the interrogation and on how a reasonable person in the suspect's position would understand the situation, not on the interrogating officer's subjective and undisclosed views. An officer's beliefs matter only if they are conveyed or otherwise manifested to the person being questioned and would affect how a reasonable person would perceive freedom to leave.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, detectives asked Lena Ortiz to come to the station to discuss a warehouse fire. She agreed, sat in an interview room for 25 minutes, and answered questions without receiving Miranda warnings. Unknown to Lena, the lead detective had already concluded she likely set the fire but never said so or otherwise conveyed that belief during the interview.

Under the governing Miranda custody standard, which fact is least relevant to whether Lena was in custody during the questioning?

Explanation. Custody turns on the objective circumstances of the interrogation and whether a reasonable person in the interviewee's position would understand the situation as involving formal arrest or a restraint on freedom of movement of that degree. An officer's subjective and undisclosed belief that the person is a suspect is irrelevant unless conveyed or otherwise manifested in a way that would affect a reasonable person's perception of freedom to leave.