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
Voluntary station-house appearance is not custodial interrogation
Leading case
Oregon v. Mathiason, 429 U.S. 492 (1977)
How courts have described it
concluding that defendant was not in custody where he appeared at police station and was questioned alone and behind closed doors
United States v. Saavedra-Martinez, 120 F. App'x 706 (9th Cir. 2005)
holding that suspect’s voluntary appearance and departure at police station for questioning was not custodial interrogation
holding a decision that was based on an unreasonable determination that suspect’s voluntary appearance and departure at police of the facts in light of the evidence presented in the State station for questioning was not custodial interrogation
Abela v. Martin (6th Cir. 2004)
holding that defendant was not in custody when he came to the station voluntarily and left 18 "without hindrance" after 30 minutes of questioning
(HC) Lopez v. Sherman (E.D. Cal. 2019)
holding that fact that defendant came to police station voluntarily and was told that he was not under arrest suggested that he was not in custody
Holguin v. Harrison, 399 F. Supp. 2d 1052 (N.D. Cal. 2005)
holding that the defendant was not in custody even after the police advised the defendant of his Miranda rights and the defendant gave a taped confession
holding that suspect was not in custody in part because interview was half an hour and suspect left without hinderance
State v. Jeremy Lambert, 255 A.3d 747 (Vt. 2021)
holding that defendant, who voluntarily attended a half-hour interview at a police station and who was immediately informed that he was not under arrest, was not “in custody”
People v. Trujillo, 938 P.2d 117 (Colo. 1997)
where police told defendant he was not under arrest, but defendant voluntarily agreed to accompany police to station house for questioning, defendant’s incriminating statements at the station house were not the product of a custodial interrogation
People v. Gillis, 883 P.2d 554 (Colo. Ct. App. 1994)
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.