People v. Stephenson

Summary

The Supreme Court of Colorado considered whether Christopher Stephenson was in custody for purposes of Miranda v. Arizona when questioned about methamphetamine found during a roadside vehicle search. The court held that retaining his driver's license, directing him to remain in or exit the vehicle, and questioning him about the drugs did not restrain him to a degree tantamount to formal arrest. It reversed the trial court's order suppressing his statements.

Holdings

1. Miranda custody requires more than a seizure or an encounter in which a reasonable person would not feel free to leave; the relevant question is whether a reasonable person would believe that he was restrained to a degree associated with a formal arrest.
2. Stephenson was not in custody when questioned about the methamphetamine because retaining his driver's license, directing him to remain in the vehicle during a records check, and directing him to stand outside the vehicle during a consensual search did not restrain him to a degree tantamount to formal arrest.
3. Deputy Post's statement, 'Come on, I found this . . . right in your seat,' did not independently establish Miranda custody under the totality of the circumstances.

Questions Presented

1. Whether Stephenson was in custody for purposes of Miranda when Deputy Post questioned him about methamphetamine found in the vehicle.
2. Whether the retention of Stephenson's driver's license, instructions to remain in or exit the vehicle, and direction to stand near the bridge during the consensual search constituted restraint equivalent to a formal arrest.

Disposition

reversed