Law School Case Brief
Stansbury v. California - 511 U.S. 318, 114 S. Ct. 1526 (1994)
It is well settled that a police officer's subjective view that the individual under questioning is a suspect, if undisclosed, does not bear upon the question whether the individual is in custody for purposes of Miranda. The same principle obtains if an officer's undisclosed assessment is that the person being questioned is not a suspect. In either instance, one cannot expect the person under interrogation to probe the officer's innermost thoughts. Save as they are communicated or otherwise manifested to the person being questioned, an officer's evolving but unarticulated suspicions do not affect the objective circumstances of an interrogation or interview, and thus cannot affect the Miranda custody inquiry. The threat to a citizen's Fifth Amendment rights that Miranda was designed to neutralize has little to do with the strength of an interrogating officer's suspicions.
Petitioner Stansbury, who was not considered by a county sheriff's office detective to be a leading suspect in the detective's homicide investigation concerning the death of a 10-year-old girl, was taken at the detective's request to a police station for questioning as a potential witness in the investigation. While being questioned at the station by the detective, petitioner, who had not been issued Miranda warnings by the detective or the other law enforcement officer who was present, said that he had used his housemate's turquoise American-made car on the night of the homicide. This statement aroused the detective's suspicion that the petitioner may have been involved in the homicide, because a car matching such a description had been implicated in the homicide. When the petitioner, in response to further questioning, admitted to prior convictions for rape, kidnapping, and child molestation, the detective terminated the questioning and another officer advised the driver of his Miranda rights. The petitioner declined to make further statements, requested an attorney, was arrested, and was charged with first-degree murder and other crimes. Concluding that the petitioner had not been in custody and thus not entitled to Miranda warnings until the detective's suspicion focused on him as a result of his mention of the turquoise car, a state trial court denied, in relevant part, the petitioner’s motion to suppress all statements made at the police station and the evidence discovered as a result of those statements. The petitioner was convicted of first-degree murder and other crimes and was sentenced to death for the murder conviction. In affirming, the Supreme Court of California concluded that one of the relevant factors in determining whether petitioner was in custody was whether the investigation was focused on him. Agreeing that suspicion focused on him only when he mentioned the car, the court found that Miranda did not bar the admission of statements made before that point.
Should the investigation focus on the petitioner before he can be deemed to be “in custody” entitled to Miranda warnings?
The United States Supreme Court reversed the decision of the Supreme Court of California and remanded the case for trial. According to the Court, a law enforcement officer's subjective and undisclosed view concerning whether a person being interrogated by law enforcement officers was a criminal suspect was irrelevant to the assessment whether the interrogatee was in custody and thus entitled to Miranda warnings, because the initial determination as to the custody issue depended on the objective circumstances of the interrogation, not on the views harbored by either the interrogating officers or the interrogate. According to the Court, it would be appropriate for the Supreme Court of California to consider in the first instance whether the objective circumstances in the record showed that the driver was in custody during his entire interrogation.
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