Opinion · Supreme Court of the United States
Stansbury v. California
511 U.S. 318
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 1994-04-26
- Topic
- litigation
How later courts describe this case
- holding that the court looks to “the objective circumstances of the interrogation, not on the subjective views” of the questioning officers or the defendant
- holding that the objective circumstances must be examined to determine whether the suspect was deprived of his freedom in a significant way
- holding that statements Hernandez made during a standoff after an attempted jail break were not the result of custodial interrogation
- holding that the “ultimate inquiry” in determining whether a person is in custody for purposes of Miranda is whether there was a “formal arrest or restraint on freedom of movement associated with a formal arrest”
- holding that a law enforcement officer’s unarticulated subjective belief as to whether the person being questioned is a criminal suspect is irrelevant to the custody determination because a custody assessment depends on the objective circumstances of an interrogation
- concluding that in determining whether a person is “in custody” for Miranda purposes, a court must determine whether there had been either a formal arrest or a “restraint on freedom of movement of the degree associated with a formal arrest” (internal quotation marks omitted)
- finding that an officer’s suspicions conveyed to a suspect may bear upon the custody determination
- observing that “determination of custody depends on the objective circumstances of the interrogation, not on the subjective views harbored by either the interrogating officers or the person being questioned”
Citator
UpLaw has not yet analyzed Stansbury v. California. The absence of a flag is not a finding that it is good law.
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Headnotes
- Criminal Law & Procedure — Miranda Warnings A person questioned by law enforcement officers after being taken into custody or otherwise deprived of freedom of action in any significant way must first be warned that he has the right to remain silent, that any statement he makes may be used as evidence against him, and that he has the right to the presence of an attorney, whether retained or appointed. 384 U.S. 436, 444 (1966)
- Criminal Law & Procedure — Miranda Warnings The obligation to administer Miranda warnings attaches only where there has been such a restriction on a person's freedom as to render him "in custody"; the ultimate inquiry is whether there was a formal arrest or a restraint on freedom of movement of the degree associated with a formal arrest. California v. Beheler, 463 U.S. 1121, 1125 (1983) (per curiam) (quoting Oregon v. Mathiason, 429 U.S. 492, 495 (1977))
- Criminal Law & Procedure — Miranda Warnings The initial determination whether a person is in custody for purposes of Miranda depends on the objective circumstances of the interrogation, not on the subjective views harbored by either the interrogating officers or the person being questioned.
- Criminal Law & Procedure — Miranda Warnings A police officer's subjective and undisclosed view that the individual being questioned is a suspect does not bear upon the question whether the individual is in custody for purposes of Miranda, because 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. Berkemer v. McCarty, 468 U.S. 420, 435, n. 22 (1984)
- Criminal Law & Procedure — Miranda Warnings An officer's knowledge or beliefs may bear upon the custody issue only if they are conveyed, by word or deed, to the individual being questioned, and then only to the extent they would affect how a reasonable person in the position of the individual being questioned would gauge the breadth of his or her freedom of action. Berkemer v. McCarty, 468 U.S. 420, 440 (1984)
- Criminal Law & Procedure — Miranda Warnings An officer's views concerning the nature of an interrogation, or beliefs concerning the potential culpability of the individual being questioned, may be one among many factors bearing upon the assessment whether that individual was in custody, but only if the officer's views or beliefs were somehow manifested to the individual under interrogation and would have affected how a reasonable person in that position would perceive his or her freedom to leave.
- Criminal Law & Procedure — Miranda Warnings An inquiry into whether the interrogating officers have focused their suspicions upon the individual being questioned, assuming those suspicions remain undisclosed, is not relevant for purposes of Miranda; the initial custody determination turns on the objective circumstances of the interrogation, not on the focus of the investigation.
- Criminal Law & Procedure — Miranda Warnings An officer's unarticulated plan has no bearing on the question whether a suspect was in custody at a particular time; the only relevant inquiry is how a reasonable person in the suspect's position would have understood his situation. Berkemer v. McCarty, 468 U.S. 420, 442 (1984)
- Criminal Law & Procedure — Miranda Warnings Miranda warnings are not required merely because the questioned person is one whom the police suspect; they are required only where there has been such a restriction on a person's freedom as to render him in custody. Oregon v. Mathiason, 429 U.S. 492, 495 (1977) (per curiam)
- Criminal Law & Procedure — Miranda Warnings A clear statement from an officer that the person under interrogation is a prime suspect is not, in itself, dispositive of the custody issue, because some suspects are free to come and go until the police decide to make an arrest; the weight and pertinence of any communications regarding the officer's degree of suspicion depend upon the facts and circumstances of the particular case.
- Criminal Law & Procedure — Miranda Warnings An officer's undisclosed views concerning whether the person being interrogated is a suspect are irrelevant to the assessment whether the person is in custody; the same principle applies where an officer's undisclosed assessment is that the person being questioned is not a suspect, since one cannot expect the person under interrogation to probe the officer's innermost thoughts.
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.
I
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 seene 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
Lee and three other plainclothes officers arrived at Stansbury’s trailer home at about 11:00 that evening. The officers surrounded the door and Lee knocked. When Stansbury answered, Lee told him the officers were investigating a homicide to which Stansbury was a possible witness and asked if he would accompany them to the police station to answer some questions. Stansbury agreed to the interview and accepted a ride to the station in the front seat of Lee’s police car.
At the station, Lieutenant Johnston, in the presence of another officer, questioned Stansbury about his whereabouts and activities during the afternoon and evening of September 28. Neither Johnston nor the other officer issued Miranda warnings. Stansbury told the officers (among other things) that on the evening of the 28th he spoke with the victim at about 6:00, returned to his trailer home after work at 9:00, and left the trailer at about midnight in his housemate’s turquoise, American-made car. This last detail aroused Johnston’s suspicions, as the turquoise car matched the description of the one Andrew Zimmerman had observed in Pasadena. When Stansbury, in response to a further question, admitted to prior convictions for rape, kidnaping, and child molestation, Johnston terminated the interview and another officer advised Stansbury of his Miranda rights.
Stansbury filed a pretrial motion to suppress all statements made at the station, and the evidence discovered as a result of those statements. The trial court denied the motion in relevant part, ruling that Stansbury was not “in custody” — and thus not entitled to Miranda warnings — until he mentioned that he had taken his housemate’s turquoise car for a midnight drive. Before that stage of the interview, the trial court reasoned, “the focus in [Lieutenant Johnston’s] mind certainly was on the other ice cream [truck] driver,” Tr. 2368; only “after Mr. Stansbury made the comment . . . describing the . . . turquoise-colored automobile” did Johnston’s suspicions “shif[t] to Mr. Stansbury,” ibid. Based upon its conclusion that Stansbury was not in custody until Johnston’s suspicions had focused on him, the trial court permitted the prosecution to introduce in its case in chief the statements Stansbury made before that time. At trial, the jury convicted Stansbury of first-degree murder, rape, kidnaping, and lewd act on a child under the age of 14, and fixed the penalty for the first-degree murder at death.
The California Supreme Court affirmed. Before determining whether Stansbury was in custody during the interview at the station, the court set out what it viewed as the applicable legal standard:
“In deciding the custody issue, the totality of the circumstances is relevant, and no one factor is dispositive. However, the most important considerations include (1) the. site of the interrogation, (2) whether the investigation has focused on the subject, (3) whether the objective indicia of arrest are present, and (4) the length and form of questioning.” 4 Cal. 4th 1017, 1050, 846 R 2d 756, 775 (1993) (internal quotation marks omitted).
We granted certiorari. 510 U. S. 943 (1993).
II
We held in Miranda that a person questioned by law enforcement officers after being “taken into custody or otherwise deprived of his freedom of action in any significant way” must first “be warned that he has a right to remain silent, that any statement he does make may be used as evidence against him, and that he has a right to the presence of an attorney, either retained or appointed.” 384 U. S., at 444. Statements elicited in noncompliance with this rule may not be admitted for certain purposes in a criminal trial. Compare id., at 492, 494, with Harris v. New York, 401 U. S. 222 (1971). An officer’s obligation to administer Miranda warnings attaches, however, “only where there has been such a restriction on a person’s freedom as to render him ‘in custody.’” Oregon v. Mathiason, 429 U. S. 492, 495 (1977) (per curiam); see also Illinois v. Perkins, 496 U. S. 292, 296 (1990). In determining whether an individual was in custody, a court must examine all of the circumstances surrounding the interrogation, but “the ultimate inquiry is simply whether there [was] a ‘formal arrest or restraint on freedom of movement’ of the degree associated with a formal arrest.” California v. Beheler, 463 U. S. 1121, 1125 (1983) (per curiam) (quoting Mathiason, supra, at 495).
Berkemer v. McCarty, 468 U. S. 420 (1984), reaffirmed the conclusions reached in Beckwith. Berkemer concerned the roadside questioning of a motorist detained in a traffic stop. We decided that the motorist was not in custody for purposes of Miranda even though the traffic officer “apparently decided as soon as [the motorist] stepped out of his car that [the motorist] would be taken into custody and charged with a traffic offense.” 468 U. S., at 442. The reason, we explained, was that the officer “never communicated his intention to” the motorist during the relevant questioning. Ibid. The lack of communication was crucial, for under Miranda “[a] policeman’s unarticulated plan has no bearing on the question whether a suspect was ‘in custody’ at a particular
It is well settled, then, 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. See F. Inbau, J. Reid, & J. Buckley, Criminal Interrogation and Confessions 232, 236, 297-298 (3d ed. 1986). 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 ques-. tioned, 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
An officer’s knowledge or beliefs may bear upon the custody issue if they are conveyed, by word or deed, to the individual being questioned. Cf. Michigan v. Chesternut, 486 U. S. 567,575, n. 7 (1988) (citing United States v. Mendenhall, 446 U. S. 544,554, n. 6 (1980) (opinion of Stewart, J.)). Those beliefs are relevant only to the extent they would affect how a reasonable person in the position of the individual being questioned would gauge the breadth of his or her “ ‘freedom of action.’” Berkemer, supra, at 440. Even a clear statement from an officer that the person under interrogation is a prime suspect is not, in itself, dispositive of the custody issue, for some suspects are free to come and go until the police decide to make an arrest. The weight and pertinence of any communications regarding the officer’s degree of suspicion will depend upon the facts and circumstances of the particular case. In sum, an officer’s views concerning the nature of an interrogation, or beliefs concerning the potential culpability of the individual being questioned, may be one among many factors that bear upon the assessment whether that individual was in custody, but only if the officer’s views or beliefs were somehow manifested to the individual under interrogation and would have affected how a reasonable person in that position would perceive his or her freedom to leave. (Of course, instances may arise in which the officer’s undisclosed views are relevant in testing the credibility of his or her account of what happened during an interrogation; but it is the objective surroundings, and not any undisclosed views, that control the Miranda custody inquiry.)
We decide on this state of the record that the California Supreme Court’s analysis of whether Stansbury was in custody is not consistent in all respects with the foregoing principles. Numerous statements in the court’s opinion are open
The State acknowledges that Lieutenant Johnston’s and the other officers’ subjective and undisclosed suspicions (or lack thereof) do not bear upon the question whether Stansbury was in custody, for purposes of Miranda, during the station house interview. It maintains, however, that the objective facts in the record support a finding that Stansbury was not in custody until his arrest. Stansbury, by contrast, asserts that the objective circumstances show that he was in custody during the entire interrogation. We think it appropriate for the California Supreme Court to consider this question in the first instance. We therefore reverse its
It is so ordered.