Supreme Court of the United States

Berkemer v. McCarty

July 2, 1984468 U.S. 420

Summary

The Court held that Miranda safeguards apply to custodial interrogation of a person suspected of any offense, including a misdemeanor traffic offense. It further held that ordinary roadside questioning during a temporary traffic stop is not custodial interrogation, so the respondent's prearrest statements were admissible, while his postarrest statements were inadmissible because he received no warnings. The Court declined to find the admission of the postarrest statements harmless because the issue was not preserved, the statements contained materially different information, and the no-contest posture produced an incomplete record.

Holding

  • Application of Miranda to misdemeanor traffic offenses. A person subjected to custodial interrogation is entitled to Miranda safeguards regardless of the nature or severity of the suspected offense, including a misdemeanor traffic offense.
  • Whether the roadside traffic stop was custodial interrogation. An ordinary traffic stop is not custody for Miranda purposes merely because the motorist is temporarily detained and questioned. Respondent was not in custody until the trooper formally arrested him.
  • Harmless-error treatment of the postarrest statements. The Court declined to determine that the erroneous admission of the postarrest statements was harmless beyond a reasonable doubt.

Docket 83-710

Cited authorities

  • Ohio Rev. Code Ann. § 4511.99
  • Ohio Rule of Criminal Procedure 12(H)
  • Ariz. Rev. Stat. Ann. § 28-622.01
  • Ariz. Rev. Stat. Ann. § 28-1054
  • Kan. Stat. Ann. § 8-2106
  • Nev. Rev. Stat. § 484.795
  • Nev. Rev. Stat. § 484.797
  • Nev. Rev. Stat. § 484.799

Cited by

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