Stansbury v. California

511 U.S. 318 (1994)

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Nature of the Case

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Facts

Ten-year-old Robyn disappeared from a playground. The next morning, Andrew Zimmerman observed a large man emerge from a turquoise American sedan and throw something into a nearby flood control channel. Zimmerman called the police, who arrived at the scene and discovered the girl's body in the channel. There was evidence that she had been raped, and the cause of death was determined to be asphyxia complicated by blunt force trauma to the head. Lieutenant Johnston, a detective, learned that Robyn had talked to two ice cream truck drivers, one being D, in the hours before her disappearance. Johnston thought Stansbury and the other driver might have some connection with the homicide or knowledge thereof. Johnston considered only the other driver to be a leading suspect. After the suspect driver was brought in for interrogation, Johnston asked D to come in for questioning as a potential witness. Officer Lee and three other plainclothes officers arrived at D's trailer home at about 11:00 that evening. The officers surrounded the door and Lee knocked. Lee told D the officers were investigating a homicide to which D was a possible witness and asked if he would accompany them to the police station to answer some questions. D accepted a ride to the station in the front seat of Lee's police car. Lieutenant Johnston, in the presence of another officer, questioned D about his whereabouts and activities during the afternoon and evening of September 28. No Miranda warnings were given. D had spoken with the victim at about 6:00, returned to his trailer home after work at 9:00, and left the trailer at about midnight in his housemate's turquoise, American-made car. Johnston became alerted because the turquoise car matched the description of the person Andrew Zimmerman had observed dumping the body. D admitted to prior convictions for rape, kidnaping, and child molestation. Johnston terminated the interview and another officer advised D of his Miranda rights. D declined to make further statements, requested an attorney, and was arrested. D was charged with first-degree murder and other crimes. D filed a pretrial motion to suppress all statements made at the station, and the evidence discovered as a result of those statements. The court denied the motion because D was not 'in custody' -- and thus not entitled to Miranda warnings -- until he mentioned that he had taken his housemate's turquoise car for a midnight drive. The court permitted the prosecution to introduce in its case-in-chief the statements D made before the warnings were given. D was convicted of first-degree murder, rape, kidnaping, and lewd act on a child under the age of 14, and fixed the penalty for first-degree murder at death. The California Supreme Court affirmed. It held that: 'In deciding the custody issue, the totality of the circumstances is relevant, and no one factor is dispositive. However, the most important considerations include (1) the site of the interrogation, (2) whether the investigation has focused on the subject, (3) whether the objective indicia of arrest are present, and (4) the length and form of questioning.' D appealed.