Master The Supreme Court held that a voluntary, noncustodial stationhouse interview does not require Miranda warnings. with this comprehensive case brief.
Oregon v. Mathiason is a cornerstone Miranda-custody case that calibrates when police must provide warnings during an interrogation. While Miranda v. Arizona mandates warnings before custodial interrogation, Mathiason clarifies that not all questioning at a police station is custodial. The decision emphasizes that “custody” turns on whether a suspect’s freedom is curtailed in a significant way, not merely on the setting, the suspect’s status as the focus of an investigation, or the use of deceptive tactics.
For law students, Mathiason is pivotal to the custody test: it underscores the objective, circumstance-driven inquiry into whether a reasonable person would feel free to terminate the interview and leave. The case, frequently paired with California v. Beheler, is invoked by courts and practitioners to show that voluntary, brief, and non-restrained interviews—even at a stationhouse—are not custodial. It sets outer boundaries for Miranda’s reach and highlights the difference between coerciveness in a colloquial sense and the legal concept of custody.
Oregon v. Mathiason, 429 U.S. 492 (1977) (per curiam)
A police officer investigating a residential burglary left a note asking respondent Mathiason to call. When he did, the officer asked him to come to the state police station to talk. Mathiason voluntarily went to the station at a mutually agreed time. He was taken into an office with the door closed for privacy, and the officer told him he was not under arrest. During the roughly 30-minute interview, the officer falsely stated that Mathiason’s fingerprints had been found at the scene, after which Mathiason admitted taking property. Only after this admission did the officer advise Mathiason of his Miranda rights, and Mathiason then gave a taped statement. He was not restrained at any point and was permitted to leave the station after the interview. Later charged with burglary, Mathiason moved to suppress his statements, arguing they were obtained in violation of Miranda because he was in custody at the time of the initial questioning. The Oregon appellate courts agreed and suppressed the statements. The U.S. Supreme Court granted certiorari.
Does Miranda require suppression of a confession obtained during a voluntary stationhouse interview when the suspect was told he was not under arrest and was allowed to leave, or, stated differently, was Mathiason in “custody” for Miranda purposes during the initial questioning?
Miranda warnings are required only for custodial interrogation. A person is in custody for Miranda purposes when they have been formally arrested or their freedom of movement has been restrained in a significant way—i.e., to a degree akin to formal arrest. The fact that questioning occurs at a police station, that the person is a suspect, or that police use deceptive tactics does not, without more, create custody.
No. Mathiason was not in custody during the interview, so Miranda warnings were not required prior to his initial admission. The confession was therefore admissible.
The Court emphasized that the Miranda safeguard is triggered by custody, not by the mere fact of police questioning or a police-dominated atmosphere. Mathiason came to the station voluntarily at the officer’s request; he was told at the outset that he was not under arrest; the interview was relatively brief; there was no physical restraint, and he left the station after it concluded. These facts indicate no restraint on freedom of movement in any significant way. The Oregon courts erred by treating factors such as stationhouse location, the suspect’s status as a focus of the investigation, and the officer’s accusatory tone and deception as dispositive of custody. While such features might contribute to subjective pressure, Miranda custody requires an objective restraint comparable to formal arrest. The officer’s false statement about fingerprints might bear on voluntariness in other contexts, but it does not convert a noncustodial interview into custodial interrogation for Miranda purposes. Because the totality of circumstances showed Mathiason was free to leave and not formally arrested or restrained to a degree associated with arrest, no Miranda warnings were required before his initial admission.
Mathiason anchors the modern custody test: Miranda applies only when a reasonable person in the suspect’s position would understand their freedom to be curtailed to a degree associated with formal arrest. It rejects a per se rule that stationhouse interviews or focus-of-investigation status are custodial. The case is routinely cited—often alongside California v. Beheler—to support the proposition that voluntary, non-restrained interviews at police facilities are noncustodial. For students, Mathiason supplies a blueprint for analyzing custody: weigh voluntariness of appearance, advisements that the person is not under arrest, duration, number of officers, physical restraints, location and openness of the setting, and whether the person was permitted to leave. It also underscores that police deception, while potentially relevant to voluntariness or due process, does not itself establish Miranda custody.
No. Mathiason holds that questioning at a police station is not per se custodial. The determinative question is whether the suspect’s freedom of movement was restrained to a degree associated with formal arrest. Voluntary appearance, being told one is not under arrest, brief duration, absence of restraints, and the ability to leave all weigh against custody.
Not by itself. Mathiason makes clear that deception does not transform a noncustodial interview into custody. While deception may be relevant to the voluntariness of a confession under due process or to the weight of the evidence, custody turns on objective restraint, not the officer’s tactics.
No. Being a suspect or the focus of an investigation does not, without more, create custody for Miranda purposes. Mathiason rejects a ‘focus’ test; the inquiry remains whether there was formal arrest or a comparable restraint on freedom.
Key factors were: (1) Mathiason voluntarily came to the station after a phone request; (2) he was told he was not under arrest; (3) the interview was brief; (4) no physical restraints or show of force were used; and (5) he was allowed to leave afterward. These circumstances, in total, showed no restraint comparable to arrest.
Together, they form the Mathiason/Beheler line: both per curiam decisions holding that voluntary stationhouse interviews with clear advisements that the suspect is not under arrest are generally noncustodial. Courts and police often rely on these cases to assess and structure noncustodial interviews.
Oregon v. Mathiason clarifies that Miranda’s protections hinge on custody, not merely on investigative focus, accusatory tone, or the setting of the interrogation. When a suspect voluntarily appears, is told he is not under arrest, is not physically restrained, and is permitted to leave after a brief interview, the interrogation is ordinarily noncustodial and Miranda warnings are not required.
For law students, Mathiason is an essential waypoint in the custody analysis. It teaches that the operative test is objective and circumstance-driven: whether, considering the totality of the situation, a reasonable person would feel their freedom was curtailed to the degree associated with formal arrest. The case provides a practical framework for evaluating exam hypotheticals and real-world interviews alike.