State v. Cruz-Mata

In State v. Cruz-Mata, 138 Ariz. 370, 372-73, 674 P.2d 1368 (1983), the Arizona Supreme Court affirmed a trial court's ruling that a defendant was not in custody where he agreed to accompany an officer to the police station for questioning, was transported in a patrol vehicle, and was questioned for approximately ninety minutes before confessing. 138 Ariz. at 373. Although a police station could be considered a "coercive environment," the court found no other objective indicia of arrest: "Defendant was not subjected to the booking process, nor were physical restraints such as handcuffs used, nor was a weapon drawn." Id. The court further noted "no force, threat or other compulsion" was used to elicit responses. Id.