State of Arizona v. Carlos Andres MacIel

Summary

The court held that Maciel was not in Miranda custody when police detained and questioned him near a vacant building during a burglary investigation, so his unwarned statements were admissible. Although his freedom of movement was curtailed, the public, brief, nonisolated, and noncoercive circumstances did not resemble station-house interrogation. The court affirmed the suppression ruling, conviction, and probationary term, and vacated the court of appeals’ opinion.