Two on Miranda custody

Defendant was not in custody for Miranda purposes. The officers went back and forth between him and his victim in his own house. He wasn’t restrained. The trial court erred in suppressing his statement. People v. Davis, 2019 CO 84, 2019 Colo. LEXIS 1031 (Oct. 7, 2019).*

Defendant wasn’t in custody when CBP talked to her as she picked up her luggage after customs. United States v. Salinas, 2019 U.S. Dist. LEXIS 173592 (D. Haw. Oct. 7, 2019).*

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