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Stansbury v. California, 511 U.S. 318 (1994)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Stansbury v. California, 511 U.S. 318 (1994)
Stansbury v. California No. 93-5770 Decided April 26, 1994 511 U.S. 318
CERTIORARI TO THE SUPREME COURT OF CALIFORNIA
Syllabus
When California police first questioned petitioner Stansbury as a possible witness to the rape and murder of a 10-year-old girl, they had another suspect. However, Stansbury became a suspect during the interview when he told police that, on the night of the murder, he drove a car matching the one seen where the girl’s body was found. After he also admitted to prior convictions for rape, kidnaping, and child molestation, officers stopped the interview, advised him of his rights under Miranda v. Arizona, 384 U.S. 436, and arrested him. The trial court denied his pretrial motion to suppress his statements to the police, reasoning that he was not "in custody" for purposes of Miranda until the officers began to suspect him. He was convicted of, inter alia, first-degree murder, and sentenced to death. In affirming, the State Supreme Court concluded that one of the relevant factors in determining whether Stansbury 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.
Held: because the initial determination of custody depends on the objective circumstances of the interrogation, an officer’s subjective and undisclosed view concerning whether the interrogee is a suspect is irrelevant in the assessment whether that person is in custody. See, e.g., Beckwith v. United States, 425 U.S. 341. Numerous statements in the State Supreme Court’s opinion are open to the interpretation that the court regarded the officers’ subjective beliefs regarding Stansbury’s status as a suspect as significant in and of themselves, rather than as relevant only to the extent they influenced the objective conditions surrounding his interrogation. The State Supreme Court should consider in the first instance whether objective circumstances show that Stansbury was in custody during the entire interrogation.
4 Cal.4th 1017, 846 P.2d 756, reversed and remanded.
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Chicago: U.S. Supreme Court, "Syllabus," Stansbury v. California, 511 U.S. 318 (1994) in 511 U.S. 318 511 U.S. 319. Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=16RMNXBF4Y3TKCT.
MLA: U.S. Supreme Court. "Syllabus." Stansbury v. California, 511 U.S. 318 (1994), in 511 U.S. 318, page 511 U.S. 319. Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=16RMNXBF4Y3TKCT.
Harvard: U.S. Supreme Court, 'Syllabus' in Stansbury v. California, 511 U.S. 318 (1994). cited in 1994, 511 U.S. 318, pp.511 U.S. 319. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=16RMNXBF4Y3TKCT.
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