What is the current state of the law in the context of "custodial interrogation"?
The following excerpt is from Spahr v. United States, 409 F.2d 1303 (9th Cir. 1969):
In Escobedo v. State of Illinois, 378 U.S. 478, 490, 84 S.Ct. 1758, 12 L.Ed.2d 977 (1964), relied on by appellants, the court discusses the stages of criminal investigation and the "focus on a particular accused." The court later set forth a specific procedure to be followed when "custodial interrogation" was contemplated. Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). The "custodial interrogation" limitation provides a point of reference for law enforcement, a means of determining
[409 F.2d 1305]
when a suspect should be warned of his right to counsel.1[409 F.2d 1305]
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