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“To safeguard this privilege, law enforcement officers must provide the well-known Miranda warnings before interrogating a person in custody.” ¶ 10 (2016).

dy for Miranda purposes if the person’s “freedom of action was significantly curtailed and, if so, [when] the environment in which [the person] was questioned presented 23 STATE v. FOSTER Opinion of the Court inherently coercive pressures similar to a station house interrogation.” ¶ 13 (2016).

¶43 A person is considered in custody for Miranda purposes if the person’s “freedom of action was significantly curtailed and, if so, when the environment in which [the person] was questioned presented inherently coercive pressures similar to a station house interrogation.” ¶ 13 (2016).

¶13 “‘Custody’ for Miranda purposes ‘is a term of art that specifies circumstances that are thought generally to present a serious danger of coercion.’” ¶ 12 (2016) (quoting Howes v. Fields, 565 U.S. 499, 508–09 (2012)).

“An error of law constitutes an abuse of discretion.”

“To safeguard this privilege, law enforcement officers must provide the well-known Miranda warnings before interrogating a person in custody.” ¶ 10 (2016).

On review of the denial of a motion to suppress, we consider only the evidence presented at the suppression hearing and view it in the light most favorable to sustaining the court’s ruling, ¶ 9 (2016), and defer to the court’s credibility determinations, ¶ 6 (App. 2010).

¶ 11 (2016) (noting that a person is in custody when he is under formal arrest).

¶35 “[L]aw enforcement officers must provide the well-known Miranda warnings before interrogating a person in custody.” ¶ 10 (2016) (citing Miranda, 384 U.S. at 478-79).

¶ 12 (2016) (citing Howes v. Fields, 565 U.S. 499, 509 (2012)).

“Custody” for Miranda purposes “is a term of art that specifies circumstances that are thought generally to present a serious danger of coercion.” ¶ 12 (2016).

AMY M. WOOD • Clerk of the Court FILED: AA [later] statements [made at the police station] should also have been suppressed based on Missouri v. Seibert, 542 U.S. 600 (2004), or Oregon v. Elstad, 470 U.S. 298 (1985).” ¶ 29 (2016).

¶ 9 (2016) (citations omitted).

The inquiry is focused not only on whether the suspect’s freedom of action was significantly curtailed, but also on “whether the environment in which he was questioned presented inherently coercive pressures similar to a station house interrogation.” -50, ¶¶ 11-13, -42 (2016).

“[W]hether a person is in custody for Miranda purposes ultimately depends on whether there is a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest.” ¶ 11 (2016) (internal quotation omitted).