California v. Beheler,
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463 U.S. 1121 (1983)
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U.S. Supreme Court
California v. Beheler, 463 U.S. 1121 (1983)
California v. Beheler
Decided July 6, 1983
463 U.S. 1121
After respondent called the police to report a homicide in which he was involved, he voluntarily accompanied them to the station house, having been told that he was not under arrest. At the station house, the police did not advise respondent of his rights under Miranda v. Arizona, 384 U. S. 436, and after an interview that lasted less than 30 minutes, he was allowed to leave. He was arrested five days later and, after receiving Miranda warnings, gave a second confession during which he admitted that his earlier interview had been given voluntarily. Subsequently, respondent was convicted in a California state court for aiding and abetting first-degree murder, the court having admitted into evidence respondent's statements at both interviews. The California Court of Appeal reversed, holding that the first police interview constituted custodial interrogation, which activated the need for Miranda warnings.
Held: Miranda warnings were not required at respondent's first interview with the police. For Miranda purposes, "custodial interrogation" means questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way. Respondent was neither taken into custody for the first interview nor significantly deprived of his freedom of action. Although the circumstances of each case must influence a determination of whether a suspect is "in custody," the ultimate inquiry is merely whether there is a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest. Miranda warnings are not required simply because the questioning takes place in a coercive environment in the station house or because the questioned person is one whom the police suspect. Cf. Oregon v. Mathiason, 429 U. S. 492.
Certiorari granted; reversed and remanded.