Does a police interview a person who was the focus of a criminal investigation need to be in custody?

4 The court noted that it had earlier rejected the notion that the "in custody" requirement was satisfied merely because the police interviewed a person who was the "focus" of a criminal investigation: "We made clear that 'Miranda implicitly defined "focus" ... as "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." ' " (California v. Beheler, supra, 463 U.S. at p. 1124, fn. 2, 103 S.Ct. at p. 3519, fn. 2, 77 L.Ed.2d at p. 1279, fn. 2.)