What is custody? Flashcards
Berkemer v. McCarty
Facts
On March 31, 1980, Trooper Williams of the Ohio State Highway Patrol observed Richard McCarty’s car weaving in and out of a lane on Interstate Highway 270. After stopping McCarty, Williams noticed signs of impairment and administered a field sobriety test, which McCarty failed. At the scene, without being informed of his rights, McCarty admitted to consuming beer and marijuana. Subsequently, McCarty was formally arrested and taken to jail, where he was again questioned without Miranda warnings and made further incriminating statements. McCarty moved to exclude these statements, arguing their admission would violate his Fifth Amendment rights since he was not informed of his constitutional rights prior to interrogation. The trial court denied the motion, and McCarty was convicted of operating a motor vehicle under the influence. His conviction was upheld by the Ohio Court of Appeals, which found that Miranda warnings are not applicable to misdemeanors. The United States Court of Appeals for the Sixth Circuit reversed, holding that Miranda warnings must be given before custodial interrogation regardless of the offense’s severity.
Issue
The Supreme Court addressed two issues: 1) Whether the Miranda decision applies to statements made during custodial interrogation for a misdemeanor traffic offense, and 2) whether the roadside questioning of a motorist detained pursuant to a traffic stop constitutes custodial interrogation under Miranda.
Holding
The Supreme Court held that the Miranda decision applies to the admissibility of statements made during custodial interrogation, regardless of whether the suspect is accused of a misdemeanor traffic offense. Additionally, the Court held that the roadside questioning of a motorist detained pursuant to a traffic stop does not constitute custodial interrogation for the purposes of Miranda.
J.D. B. v North Carolina
[W]hether the Miranda custody analysis includes consideration of a juvenile suspect’s age.” More specifically, whether “a child’s age ‘would have affected how a reasonable person’ in the suspect’s position ‘would perceive his or her freedom to leave
Yes. “So long as the child’s age was known to the officer at the time of police questioning, or would have been objectively apparent to any reasonable officer, its inclusion in the custody analysis is consistent with the objective nature of the test. . . . Just as police officers are competent to account for other objective circumstances that are a matter of degree such as the length of questioning or the number of officers present, so too are they competent to evaluate the effect of relative age.”
The Supreme Court reversed the judgment of the North Carolina Supreme Court and remanded the case to the lower court to determine whether, taking his age into consideration, J.D.B. was in custody when he was interrogated.
