Miranda & Interrogations 2

What was the key holding of Duckworth v. Eagan (1989)?

Miranda warnings do not need to match the exact phrasing in Miranda v. Arizona as long as the suspect is fully informed of their rights.

What controversial language did officers use in Duckworth?

“We have no way of giving you a lawyer, but one will be appointed for you if and when you go to court.”

Why did SCOTUS uphold the warning in Duckworth?

Officers were anticipating a common question, and although not elegant, it was accurate and conveyed the essence of the rights.

Why is Duckworth considered a “heavy blow” to Miranda?

Because it signals that adaptations and non-literal warnings are acceptable so long as the core substance is conveyed.

What warnings were challenged in Florida v. Powell (2010)?

“You have the right to talk to an attorney before questioning, and at any point during questioning you may invoke that right.”

Why did the Court uphold the warning in Powell?

The combined language reasonably conveyed both the right to consult an attorney before and during interrogation.

What was the dissent’s view in Powell?

SCOTUS approved the first omission of an essential Miranda right; the dissent said the warnings failed to communicate the right properly.

When are Miranda warnings required?

Only when the suspect is in custody AND subject to interrogation.

How is “custody” defined for Miranda?

When a suspect is taken into custody or otherwise deprived of freedom in a significant way.

Is custody based on officer or suspect subjective beliefs?

No. Custody is based on objective circumstances — how a reasonable person would gauge their freedom of action.

Does being the “focus” of an investigation trigger Miranda?

No. A person can be the focus but not in custody.

Does questioning in a police station automatically mean custody?

No. Voluntary station interviews are often non-custodial (Mathiason, Beheler).

Is a Terry stop “custody” for Miranda purposes?

No. Terry stops = temporary, limited, not custody.

Can a coercive environment alone create Miranda custody?

No. Must be the functional equivalent of formal arrest.

Why does the IRS sometimes give Miranda warnings even outside custody?

To make it clear statements were voluntary, not compelled.

What did Beckwith hold about custody vs focus?

Focus ≠ Custody. Even if the IRS targets someone, they are not “in custody” unless restraint = formal arrest.

What is the custody test from Beckwith?

Whether a reasonable person would believe they were effectively under arrest.

What did Berkemer decide about traffic stops?

Routine traffic stops are not custody: brief, temporary, less intimidating.

Does officer subjective intent matter under Berkemer?

No. Only the suspect’s perspective matters.

Why wasn’t the probationer in Murphy in custody?

He voluntarily attended a meeting with his probation officer in a familiar environment → not restrained.

What key fact made Mathiason and Beheler non-custodial?

Both were told they were not under arrest and were free to leave.

What factor must be considered in juvenile Miranda custody?

Age. Reasonable child standard applies.

What was the dissent’s concern in J.D.B.?

Adding age makes Miranda more subjective and less one-size-fits-all.

Is a prisoner automatically “in custody” for Miranda?

No. Prison status alone doesn’t equal custody; Fields was told he was free to end the meeting.

What counts as interrogation under Miranda?

Direct questioning or its functional equivalent.

What is “functional equivalent” according to Rhode Island v. Innis?

Words or actions police should know are reasonably likely to elicit an incriminating response.

What two things must be considered under Innis?

• Perception of the suspect

• What police should reasonably foresee

Why was there no interrogation in Innis?

No evidence officers knew their conversation would elicit a response → not reasonably foreseeable.

If a suspect blurts out information, is that interrogation?

No. Volunteered statements ≠ interrogation.

Why wasn’t the conversation with the wife in Mauro interrogation?

Wife was not an agent, and police did nothing to provoke statements.

Why didn't Miranda apply in Perkins?

No overt police interrogation; undercover questioning ≠ Miranda interrogation.

Why didn’t the 6th Amendment apply in Perkins?

6A is offense-specific; suspect wasn’t charged with the crime he discussed with the undercover officer.

What did the dissent argue in Perkins?

Covert police work should not bypass constitutional protections.

Are field sobriety tests testimonial?

No. They are physical evidence, so no Miranda needed.

Are booking questions subject to Miranda?

No. They are administrative, even though responses convey factual info.

Why was the “6th birthday” question testimonial?

It required Muniz to use mental processes and reveal information from his mind.

Is slurred speech testimonial?

No. It is physical evidence.

Why were statements during sobriety tests admissible?

They were blurted out → not the product of interrogation.

What is the public safety exception from New York v. Quarles?

Police may ask questions without Miranda when necessary to neutralize a threat to public safety.

Why did the officer ask “Where’s the gun?” without Miranda?

Missing gun posed immediate danger to officers or civilians.

What does Quarles emphasize about Miranda’s nature?

Miranda is a judicially-created prophylactic rule, not a constitutional mandate.