## Facts

- A 10-year-old girl disappeared in Baldwin Park, California; her body was later found in a flood control channel, and evidence indicated rape and death by asphyxia and blunt force trauma.
- Police learned the victim had recently spoken with two ice cream truck drivers, including Robert Edward Stansbury.
- Late at night, four plainclothes officers went to Stansbury’s trailer, positioned themselves around the door, told him he was a possible witness in a homicide investigation, and asked him to come to the station; he agreed and rode in the front seat of a police car.
- At the station, an officer questioned Stansbury about his activities on the day of the crime without providing Miranda warnings.
- During questioning, Stansbury stated he had driven a car matching the type seen near where the body was found and disclosed prior convictions for rape, kidnapping, and child molestation.
- Officers then stopped questioning, gave Miranda warnings, and arrested Stansbury; after warnings, he invoked counsel and declined to speak further.
- The trial court denied a motion to suppress the pre-warning statements, reasoning Stansbury was not in custody until officers began to suspect him; the California Supreme Court affirmed, treating whether the investigation had “focused” on him as a relevant custody factor.

## Issues

1. Whether Miranda “custody” may be determined based on officers’ subjective, undisclosed belief about whether the interviewee is a suspect.
2. Whether the correct custody inquiry instead turns on the objective circumstances and how a reasonable person would understand his freedom to end questioning and leave.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that an officer’s subjective and undisclosed view of whether the person is a suspect is irrelevant to whether the person is in custody for Miranda purposes.
- The Court instructed the state court to apply the proper objective test and determine whether, under the objective circumstances, Stansbury was in custody during the pre-warning interview.
- The Court did not decide whether Stansbury was actually in custody; it limited its ruling to correcting the governing legal standard.

## Legal Principles

- Miranda custody is assessed under an objective standard: whether, under the circumstances, there was a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest.
- The relevant inquiry is how a reasonable person in the interviewee’s position would have understood the situation, not what police or the interviewee actually thought.
- Police officers’ subjective beliefs are relevant only if conveyed to the interviewee by word or conduct and only to the extent that communication would affect a reasonable person’s assessment of freedom of action.
- “Focus of investigation” or being a “prime suspect” is not independently dispositive of custody; it matters only insofar as it is objectively manifested in a way that would signal restraint comparable to arrest.

## Conclusion

The Court held that Miranda custody cannot turn on officers’ unexpressed suspicions and must be evaluated solely from the objective circumstances as they would be understood by a reasonable person, remanding for application of that standard to the stationhouse questioning.


Stansbury v. California, 511 U.S. 318 (1994)