California, United States of America
The following excerpt is from The People v. Schuster, F055692, No. F03904715-0 (Cal. App. 2011):
Prior to trial, Schuster unsuccessfully sought to suppress the statements she made to police in the interview of July 11 through 12 as having been taken in violation of Miranda v. Arizona (1966) 384 U.S. 436 (Miranda).13 On appeal, she contends the interview became custodial when detectives discovered her cell phone in her car; hence, Miranda advisements should have been given at that point, and failure to do so should have resulted in suppression of all evidence of statements and events occurring after that point. We disagree.
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