Which case held that Miranda does not apply unless the suspect is in police custody?

Which case held that Miranda does not apply unless the suspect is in police custody?

• A. Berkemer v. McCarty, 1984
• B. Rhode Island v. Innis, 1980
• C. Dickerson v. United States, 2000
• D. Harris v. New York, 1971

Answer: (A)

The key idea is that Miranda warnings apply only when a person is in police custody and being interrogated. Berkemer v. McCarty clarifies that a routine, noncustodial roadside detour—like a traffic-stop questioning—is not custody for Miranda purposes. So, during that moment, the suspect isn’t entitled to Miranda warnings. Custody begins when the person is formally arrested or otherwise restrained in a manner akin to an arrest, after which Miranda warnings are required before interrogation. The other cases deal with related but different aspects: what counts as interrogation (Innis), the continuing validity of Miranda as a constitutional requirement (Dickerson), and whether uncounseled statements can be used to impeach a witness (Harris)—not the custody threshold for applying Miranda.

The key idea is that Miranda warnings apply only when a person is in police custody and being interrogated. Berkemer v. McCarty clarifies that a routine, noncustodial roadside detour—like a traffic-stop questioning—is not custody for Miranda purposes. So, during that moment, the suspect isn’t entitled to Miranda warnings. Custody begins when the person is formally arrested or otherwise restrained in a manner akin to an arrest, after which Miranda warnings are required before interrogation.

The other cases deal with related but different aspects: what counts as interrogation (Innis), the continuing validity of Miranda as a constitutional requirement (Dickerson), and whether uncounseled statements can be used to impeach a witness (Harris)—not the custody threshold for applying Miranda.