Orozco v. Texas
Citation and Court
394 U.S. 324 (1969) — Supreme Court of the United States
Facts
Four officers entered Orozco’s bedroom at 4 a.m. and questioned him about a shooting while he lay in bed. He was not under formal arrest, but testimony established he was not free to leave. Without Miranda warnings, he made incriminating statements. The State argued Miranda applied only to station-house interrogations.
Issue
Whether Miranda applies to custodial interrogation in a suspect’s home when he is not free to leave.
Holding
Yes; Miranda protections apply whenever a person is subjected to custodial interrogation, regardless of whether the questioning occurs at the police station or elsewhere, including the suspect’s own home.
Rule / Doctrine
Miranda is triggered by custody — a formal arrest or a restraint on freedom of movement of the degree associated with arrest — plus interrogation. The location of the questioning is irrelevant. When police enter a suspect’s home under circumstances where he is effectively deprived of his freedom of action, Miranda warnings are required before interrogation may proceed.
Significance
Confirmed that Miranda is not limited to the police station but applies wherever custodial conditions exist, including a suspect’s own home. Reinforced the custody-focused nature of the Miranda analysis.