custodial interrogation requiring Miranda warning (Pennsylvania) · Go Syfert
← Pennsylvania issues

custodial interrogation requiring Miranda warning in Pennsylvania

6 Pennsylvania opinions name it 2 courts 1999–2022 2 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Com. v. Carter, W.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
2 sentences

2022Therein, in granting the defendant’s suppression motion, the trial court concluded that an encounter between the police and the defendant was “a custodial interrogation requiring Miranda warnings and a valid waiver, and that [the defendant] did not knowingly, intelligently, or voluntarily waive his Miranda rights.” Carter, 234 A.3d at 732 (citation to trial court opinion omitted).

2022Specifically, the trial court held the defendant did not voluntarily waive his Miranda rights since the Commonwealth failed to establish the defendant was aware of the general nature of “‘the transaction giving rise to the investigation[.]’” Id. at 733 (citations omitted).

11
Commonwealth v. Johnsongreen
pa · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See Ellis, Johnson, supra. Nor for that matter, did the officer's follow-up inquiry, as to the gun's ownership escalate or transform the situation to a custodial interrogation.

11
Commonwealth v. Turnergreen
pasuperct · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Commonwealth v. Turner, 772 A.2d 970, 977 (Pa. Super. 2001) (en banc) (stating that while traffic stops “curtail significantly” an individual’s freedom, the detention is typically temporary and brief and does not generally rise to the level of custodial interrogation).

11
Commonwealth v. Nestergreen
pa · 1998 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
2 sentences

1999We have held that we will examine the totality of the circumstances surrounding statements given during noncustodial interrogations, “because a noncustodial interrogation ‘might possibly in some situations, by virtue of some special circumstances,’ result in an involuntary confession.” Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998) (quoting Beckwith v. United States, 425 U.S. 341, 347-48 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1976)).

1999We have held that we will examine the totality of the circumstances surrounding statements given during noncustodial interrogations, “because a noncustodial interrogation ‘might possibly in some situations, by virtue of some special circumstances,’ result in an involuntary confession.” Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998) (quoting Beckwith v. United States, 425 U.S. 341, 347-48 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1976)).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Commonwealth v. Perry green
pasuperct · 1998
2 sentences

2018However, Johnson challenged four different statements he made to police and, with respect to the statement made while in the ambulance, the Supreme Court specifically noted that appellant “does not claim that this questioning amounted to a custodial interrogation requiring Miranda warning.” Id. (emphasis added).

2018Rather, Johnson argued that his physical condition was so severe that “any statement given to police was not given knowingly, voluntarily, and intelligently.” Id.

12018–2018
Minnesota v. Murphy green
scotus · 1984
1 sentence

2012Id., at 429-30, 104 S.Ct. 1136 ; Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966).

12012–2012
Miranda v. Arizona green
scotus · 1966
2 sentences

2012Id., at 429-30, 104 S.Ct. 1136 ; Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966).

2012Id., at 429-30, 104 S.Ct. 1136 ; Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966).

12012–2012
Beckwith v. United States green
scotus · 1976
2 sentences

1999We have held that we will examine the totality of the circumstances surrounding statements given during noncustodial interrogations, “because a noncustodial interrogation ‘might possibly in some situations, by virtue of some special circumstances,’ result in an involuntary confession.” Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998) (quoting Beckwith v. United States, 425 U.S. 341, 347-48 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1976)).

1999We have held that we will examine the totality of the circumstances surrounding statements given during noncustodial interrogations, “because a noncustodial interrogation ‘might possibly in some situations, by virtue of some special circumstances,’ result in an involuntary confession.” Commonwealth v. Nester, 551 Pa. 157 , 709 A.2d 879, 882 (1998) (quoting Beckwith v. United States, 425 U.S. 341, 347-48 , 96 S.Ct. 1612 , 48 L.Ed.2d 1 (1976)).

11999–1999

Where else courts name it

NY 13 (1993–2025) OH 12 (2012–2025) FL 6 (1983–2008) PA 6 (1999–2022) TX 5 (2011–2018) CA 3 (2012–2018) NJ 2 (2017–2021) MT 2 (1999–2003)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check