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The ultimate "in custody" determination for Miranda purposes fits within the class of cases involving issues of law. Two discrete inquiries are essential to the determination: first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a reasonable person have felt he or she was not at liberty to terminate the interrogation and leave. Once the scene is set and the players' lines and actions are reconstructed, the court must apply an objective test to resolve the ultimate inquiry: was there a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest. The first inquiry is distinctly factual. State-court findings on these scene- and action-setting questions attract a presumption of correctness under 28 U.S.C.S. § 2254(d). The second inquiry, however, calls for application of the controlling legal standard to the historical facts. This ultimate determination presents a mixed question of law and fact qualifying for independent review.
During a two-hour, tape-recorded session at Alaska state trooper head-quarters, petitioner Thompson confessed he had killed his former wife. Thompson maintained that the troopers gained his confession without according him the warnings required by Miranda v. Arizona, 384 U.S. 436, 16 L. Ed. 2d 694, 86 S. Ct. 1602. The Alaska trial court denied his motion to suppress the confession, however, ruling that he was not "in custody" for Miranda purposes, therefore the troopers were not required to inform him of his Miranda rights. After a trial at which the prosecution played the tape-recorded confession, the jury found Thompson guilty of first-degree murder, and the Court of Appeals of Alaska affirmed his conviction. The Federal District Court denied Thompson's petition for a writ of habeas corpus, and the Ninth Circuit affirmed. Both courts held that a state court's ruling that a defendant was not "in custody" for Miranda purposes qualifies as a "fact" determination entitled to a presumption of correctness under 28 U.S.C. § 2254(d).
Do state-court "in custody" rulings, made to determine whether Miranda warnings are due, qualify for a presumption of correctness under § 2254(d)?
The Supreme Court ruled that the presumption of correctness did not apply to a custody determination because that issue was not a question of fact, but was a mixed question of law and fact, requiring an independent review by the federal court. Although the historical fact determinations were factual and entitled to the § 2254(d) presumption, the ultimate objective inquiry of whether there was a formal arrest or restrain of movement similar to arrest was a legal matter for independent federal determination.