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California v. Beheler


After the defendant called the police to report a homicide in which he was involved, he voluntarily accompanied them to the station house. The officers told the defendant that he was not under arrest. At the station house, the defendant talked about the murder in an interview that lasted less than 30 minutes. The police did not advise him of his Miranda rights. The defendant was permitted to return to his home, and he was arrested five days later. After he was advised of his Miranda rights at that time, he waived those rights and gave a second confession.


Whether the defendant was in custody at the time of his first interview?


No. A person is not in custody if he or she voluntarily goes to a police station and is allowed to leave unhindered by the police after a brief interview.


The Court held that Miranda warnings were not required at the defendant’s first interview with the police. Miranda warnings are not necessary unless there is police custodial interrogation. The Court found that the defendant was neither taken into custody for the first interview nor significantly deprived of his freedom of action. Although the circumstances of each case must be considered in determining whether a suspect is “in custody,” the ultimate inquiry is 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 government suspects. Also, the length of time that elapses between the commission of a crime and a police interview that takes place when a person voluntarily comes to the police station has no relevance in determining whether a Miranda warning is required. The fact that a person who voluntarily engages in an interview with the government is unaware of the consequences of his participation does not transform the voluntary interview into custody.


463 U.S. 1121; 103 S. Ct. 3517 (1983)

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