## Facts

- An Ohio state trooper stopped Richard McCarty after observing his car weave on an interstate highway and ordered him out of the vehicle.
- The trooper observed McCarty had difficulty standing and decided McCarty would be charged with a traffic offense and would not be permitted to leave, but the trooper did not tell McCarty he was under arrest.
- McCarty failed a field sobriety test, and the trooper asked if he had used intoxicants; McCarty admitted to drinking beers and smoking marijuana shortly before.
- The trooper then formally arrested McCarty and transported him to the county jail.
- At the jail, a chemical test did not detect alcohol in McCarty’s blood, but officers continued questioning and McCarty made further incriminating statements.
- No officer administered Miranda warnings during the roadside encounter or the later station-house questioning.
- Ohio charged McCarty with a first-degree misdemeanor for operating a motor vehicle under the influence of alcohol and/or drugs.
- After the state courts upheld admission of the statements, McCarty sought federal habeas relief; the Sixth Circuit held Miranda applied and deemed at least the post-arrest statements inadmissible.

## Issues

1. Whether Miranda warnings are required for custodial interrogation when the suspected offense is a misdemeanor traffic offense rather than a felony.
2. Whether routine roadside questioning during an ordinary traffic stop constitutes “custody” for Miranda purposes.

## Decision

- The Supreme Court affirmed in part and reversed in part the Sixth Circuit.
- The Court held Miranda applies to custodial interrogation regardless of whether the offense is a felony or a misdemeanor.
- The Court held ordinary roadside traffic stops are generally not “custodial,” so Miranda warnings are not required before routine questioning during such stops.
- The Court held McCarty was in custody once formally arrested and taken to jail; because he was questioned there without Miranda warnings, his post-arrest station-house statements were inadmissible.
- McCarty’s pre-arrest roadside statements were admissible because the roadside encounter was not custodial.

## Legal Principles

- Miranda safeguards apply whenever a suspect is subjected to custodial interrogation, without regard to the nature or severity of the offense.
- “Custody” for Miranda turns on whether a reasonable person’s freedom of action is curtailed to a degree associated with formal arrest.
- Ordinary traffic stops are typically brief, occur in public view, and resemble investigatory detentions; they usually do not amount to Miranda custody.
- Formal arrest and station-house interrogation are custodial settings that require Miranda warnings before interrogation; unwarned custodial statements are inadmissible.

## Conclusion

The Court held that Miranda’s protections do not depend on felony versus misdemeanor classifications, but clarified that routine roadside traffic stops are generally noncustodial; warnings are required only when the encounter becomes arrest-like, such as after formal arrest and station-house questioning.


Berkemer v. McCarty, 468 U.S. 420 (1984)