Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
Custody, Not Investigative Focus, Triggers Miranda
Leading case
Beckwith v. United States, 425 U.S. 341 (1976)
How courts have described it
concluding that three-hour interview in suspect’s home did not implicate Miranda
United States v. Hughes, 640 F.3d 428 (1st Cir. 2011)
holding that being the focus of law enforcement’s investigation was not being “in custody” so as to trigger Miranda
United States v. Magana, 70 F. App'x 859 (6th Cir. 2003)
holding that Miranda warnings are not required in noncustodial interview even where the investigation had focused on the taxpayer
United States v. Rigoberto Raciel Mesa, 638 F.2d 582 (3d Cir. 1980)
stating that "an extension of the Miranda requirements [to include non-custodial interrogation] would cut this Court's holding in that case completely loose from its own explicitly stated rationale"
State v. Smith, 38 P.3d 1149 (Alaska 2002)
noting that it is the custodial nature of the interrogation that triggers the need for compliance with Miranda
State v. Schinzel, 45 P.3d 1224 (Ariz. Ct. App. 2002)
Related doctrines
- Cessation of interrogation upon invocation of Miranda rights
- Routine booking question exception
- Routine traffic stop is not custody under Miranda
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.