Stansbury v. California
Annotate this Case
511 U.S. 318 (1994)
OCTOBER TERM, 1993
STANSBURY v. CALIFORNIA
CERTIORARI TO THE SUPREME COURT OF CALIFORNIA No. 93-5770. Argued March 30, 1994-Decided April 26, 1994
When California police first questioned petitioner Stansbury as a possible witness to the rape and murder of a 10-year-old girl, they had another suspect. However, Stansbury became a suspect during the interview, when he told police that, on the night of the murder, he drove a car matching the one seen where the girl's body was found. After he also admitted to prior convictions for rape, kidnaping, and child molestation, officers stopped the interview, advised him of his rights under Miranda v. Arizona, 384 U. S. 436, and arrested him. The trial court denied his pretrial motion to suppress his statements to the police, reasoning that he was not "in custody" for purposes of Miranda until the officers began to suspect him. He was convicted of, inter alia, first-degree murder and sentenced to death. In affirming, the State Supreme Court concluded that one of the relevant factors in determining whether Stansbury 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.
Held: Because the initial determination of custody depends on the objective circumstances of the interrogation, an officer's subjective and undisclosed view concerning whether the interrogee is a suspect is irrelevant to the assessment whether that person is in custody. See, e. g., Beckwith v. United States, 425 U. S. 341. Numerous statements in the State Supreme Court's opinion are open to the interpretation that the court regarded the officers' subjective beliefs regarding Stansbury's status as a suspect as significant in and of themselves, rather than as relevant only to the extent they influenced the objective conditions surrounding his interrogation. The State Supreme Court should consider in the first instance whether objective circumstances show that Stansbury was in custody during the entire interrogation.
4 Cal. 4th 1017,846 P. 2d 756, reversed and remanded.
Robert M. Westberg, by appointment of the Court, 510 U. S. 1009, argued the cause for petitioner. With him on the briefs were David S. Winton and Joseph A. Hearst.
Aileen Bunney, Deputy Attorney General of California, argued the cause for respondent. With her on the brief were Daniel E. Lungren, Attorney General, George Will iamson, Chief Assistant Attorney General, Ronald A. Bass, Senior Assistant Attorney General, and Ronald E. Niver, Deputy Attorney General. *
This case concerns the rules for determining whether a person being questioned by law enforcement officers is held in custody, and thus entitled to the warnings required by Miranda v. Arizona, 384 U. S. 436 (1966). We hold, not for the first time, that an officer's subjective and undisclosed view concerning whether the person being interrogated is a suspect is irrelevant to the assessment whether the person is in custody.
Ten-year-old Robyn Jackson disappeared from a playground in Baldwin Park, California, at around 6:30 p.m. on September 28, 1982. Early the next morning, about 10 miles away in Pasadena, Andrew Zimmerman observed a large man emerge from a turquoise American sedan and throw something into a nearby flood control channel. Zimmerman called the police, who arrived at the scene and discovered the girl's body in the channel. There was evidence that she had been raped, and the cause of death was determined to be asphyxia complicated by blunt force trauma to the head.
Lieutenant Thomas Johnston, a detective with the Los Angeles County Sheriff's Department, investigated the hom-
*Briefs of amici curiae urging affirmance were filed for the Orange County District Attorney, State of California, by Michael R. Capizzi and Devallis Rutledge; for Americans for Effective Law Enforcement, Inc., by Bernard J. Farber, Fred E. Inbau, Wayne W Schmidt, and James P. Manak; and for the Criminal Justice Legal Foundation by Kent S. Scheidegger.
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