California v. Beheler

In California v. Beheler (1983) 463 U.S. 1121, the Supreme Court reversed a California appellate court finding of custodial interrogation, rejecting the same kind of arguments Hernandez advances: "The appellate court focused on the fact that the interview took place in the station house, that before the station house interview the police had already identified defendant as a suspect in the case because defendant had discussed the murder with police earlier, and that the interview was designed to produce incriminating responses." Beheler, supra, 463 U.S. 1121, relied heavily on Mathiason, supra, 429 U.S. 492, a case involving "remarkably similar" facts to those presented in Beheler. (Beheler, supra, 463 U.S. at p. 1123.) In Mathiason, supra, 429 U.S. 492, "the police initiated contact with defendant, who agreed to come to the patrol office. There, the police conducted an interview after informing defendant that they suspected him of committing a burglary, and that the truthfulness of any statement that he made would be evaluated by the district attorney or a judge. The officer also falsely informed defendant that his fingerprints were found at the scene of the crime. Defendant then admitted to his participation in the burglary. The officer advised defendant of his Miranda rights, and took a taped confession, but released him pending the district attorney's decision to bring formal charges. The interview lasted for 30 minutes." (Beheler, supra, 463 U.S. at pp. 1123-1124.) "'Such a noncustodial situation is not converted to one in which Miranda applies simply because a reviewing court concludes that, even in the absence of any formal arrest or restraint on freedom of movement, the questioning took place in a "coercive environment."' " (Beheler, supra, 463 U.S. at p. 1124, citing Mathiason, supra, 429 U.S. at p. 495.) Neither the fact that the police had already determined that defendants in Mathiason and Beheler were prime suspects nor the use of interview techniques designed to elicit incriminating responses was determinative on the issue of whether defendants were in custody. (Beheler, supra, 463 U.S. at pp. 1123-1125.)