Laury v. State
In Laury v. State, 260 A.2d 907, 908 (Del. 1969), the Delaware Supreme Court declined to extend the Miranda rules to the "routine, initial, on-scene investigation by the police."
In Laury, the defendants were questioned at the scene of a street-corner robbery without Miranda warnings. Id. The defendants were then taken to the police station where they were questioned again, with Miranda warnings. Id.
The Court held that the "practicalities of effective police investigation at the scene, immediately after the commission of a crime, require the police to have an unrestricted scope of general interrogation as to those found there." Id. The Miranda rules are first applicable at the accusatory stage or during custodial interrogation. Id.