Stansbury v. California

Facts of the Case

Petitioner Stansbury, who was not considered by a county sheriff’s office detective to be a leading suspect in the detective’s homicide investigation concerning the death of a 10-year-old girl, was taken at the detective’s request to a police station for questioning as a potential witness in the investigation. While being questioned at the station by the detective, petitioner, who had not been issued Miranda warnings by the detective or the other law enforcement officer who was present, said that he had used his housemate’s turquoise American-made car on the night of the homicide. This statement aroused the detective’s suspicion that the petitioner may have been involved in the homicide, because a car matching such a description had been implicated in the homicide. When the petitioner, in response to further questioning, admitted to prior convictions for rape, kidnapping, and child molestation, the detective terminated the questioning and another officer advised the driver of his Miranda rights. The petitioner declined to make further statements, requested an attorney, was arrested, and was charged with first-degree murder and other crimes. Concluding that the petitioner had not been in custody and thus not entitled to Miranda warnings until the detective’s suspicion focused on him as a result of his mention of the turquoise car, a state trial court denied, in relevant part, the petitioner’s motion to suppress all statements made at the police station and the evidence discovered as a result of those statements. The petitioner was convicted of first-degree murder and other crimes and was sentenced to death for the murder conviction. In affirming, the Supreme Court of California concluded that one of the relevant factors in determining whether petitioner was in custody was whether the investigation was focused on him. Agreeing that suspicion focused on him only when he mentioned the car, the court found that Miranda did not bar the admission of statements made before that point.

Question

May a trial court determine that a criminal defendant is not in custody for Miranda purposes on the basis of police officers’ subjective and undisclosed conclusions that they did not consider the defendant a suspect?

CONCLUSION

No. In a per curiam opinion, the Supreme Court reversed the lower court and remanded. The Court held that an officer’s subjective view is irrelevant to the determination of whether a person being interrogated is “in custody.” On remand, the Supreme Court of California should consider whether the objective circumstances showed that Stansbury was in custody during his entire interrogation. Justice Harry A. Blackmun concurred, writing that the death penalty cannot be imposed fairly within the constraints of the Constitution.

Case Information

  • Citation: 511 US 318 (1994)
  • Argued: Mar 30, 1994
  • Decided Apr 26, 1994Granted: Nov 1, 1993