Does a police station interview take place in a custodial setting?

Defendant also renews his objection that the interview itself took place in a custodial setting because it occurred in the jail area of the police station. Station house interviews are not necessarily custodial, however, as the high court has explained. In Oregon v. Mathiason (1977) 429 U.S. 492, 97 S.Ct. 711, 50 L.Ed.2d 714, for example, the high court found that the defendant was not in custody, though he was questioned in the allegedly coercive environment of the police station. In that case, the defendant acceded to a police officer's request to be interviewed at the police station. The officer told the defendant he was not under arrest, but the interview was accusatory to the extent that the officer told the defendant he was a suspect in a burglary, and falsely told him that his fingerprints had been found on the scene. The court nevertheless found that custody had not been established. "Such a noncustodial situation is not converted to one in which Miranda applies simply because a reviewing court concludes that, even in the absence of any formal arrest or restraint on freedom of movement, the questioning took place in a 'coercive environment.' Any interview of one suspected of a crime by a police officer will have coercive aspects to it, simply by virtue of the fact that the police officer is part of a law enforcement system which may ultimately cause the suspect to be charged with a crime. But police officers are not required to administer Miranda warnings to everyone whom they question. Nor is the requirement of warnings to be imposed simply because the questioning takes place in the station house, or because the questioned person is one whom the police suspect. Miranda warnings are required only where there has been such a restriction on a person's freedom as to render him 'in custody.' " (Oregon v. Mathiason, supra, 429 U.S. at p. 495, 97 S.Ct. at p. 714, italics added.)

Similarly, in California v. Beheler, supra, 463 U.S. 1121, 103 S.Ct. 3517, the court found that a person who called the police to report that his associate had killed someone and who agreed to accompany the police to the station house for questioning was not in custody during the 30-minute interview that followed. The court rejected the lower court's focus on the facts that the interview took place in the station house and that the defendant was a suspect when he was questioned. "[W]e have explicitly recognized that Miranda warnings are not required 'simply because the questioning takes place in the station house or because the questioned person is one whom the [9 Cal.4th 834] police suspect.' " (California v. Beheler, supra, 463 U.S. at p. 1125, 103 S.Ct. at p. 3520.)