Stansbury v. California
Citation and Court
511 U.S. 318 (1994) — Supreme Court of the United States
Facts
Officers investigating a child’s murder interviewed Stansbury as a potential witness. The officers privately believed he was a suspect but did not communicate that belief to him. Stansbury was not formally told he was a suspect until late in the interview, at which point he was Mirandized. His pre-warning statements were used at trial.
Issue
Whether an officer’s undisclosed suspicion that a person is a suspect is relevant to the Miranda custody determination.
Holding
No; the custody determination is purely objective and does not turn on an officer’s subjective, uncommunicated belief about whether the person being interviewed is a suspect.
Rule / Doctrine
Miranda custody is determined by reference to how a reasonable person in the suspect’s position would have understood his situation, not by the officer’s privately held views about guilt. An officer’s undisclosed intent to charge or belief that the interviewee is the perpetrator does not transform the encounter into custody. Only those circumstances actually communicated or apparent to the person matter.
Significance
Confirmed the objective, external nature of the Miranda custody test and clarified that police are not required to reveal their subjicions to trigger Miranda warnings. Defendants cannot rely on hidden police intent to establish custody.