Brown v. State, 156 A.3d 839

Terrance J. Brown, treated for multiple gunshot wounds, was met at the hospital by a Cambridge detective who said he came to “obtain” Brown for a statement and transported him in a marked cruiser to the police station while Brown wore hospital scrubs and a bandage.
Brown was not handcuffed, was told multiple times he was not under arrest and that he was a victim, but was never told he was free to leave or refused transport; his car had been towed as possible evidence.
At the station Brown was escorted through a non-public entrance to a second-floor, windowless interrogation room; he was left alone briefly and then questioned by Detective Flynn.
Detective Flynn questioned Brown for about six minutes before issuing Miranda warnings; Brown made incriminating statements during those pre-warning six minutes; after warnings Brown requested counsel and later was arrested.
The suppression court granted Brown’s motion to suppress the pre-warning statements; the Court of Special Appeals reversed; the Maryland Court of Appeals remanded for factual findings and then held Brown was in custody for Miranda purposes and affirmed suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Brown in Miranda custody during the ~6 minutes of pre-warning interrogation?	Brown: objective totality shows a reasonable person would not feel free to leave (hospital transport by police while wounded, nonpublic entry, isolated room, car seized).	State: Brown consented/acquiesced, was told he was not under arrest and a victim, not restrained, interrogator plain-clothed; these point away from custody.	Held: Brown was in custody for Miranda purposes for the entire pre-warning interrogation; statements suppressed.
Do suppression-court factual findings control appellate review here?	Brown: findings must be accepted unless clearly erroneous; appellate court shouldn’t fill factual gaps against prevailing party.	State: Court of Special Appeals relied on record to find no custody.	Held: Because suppression court issued findings on remand, appellate review accepts those findings and Court of Appeals applied the objective Miranda test de novo to those facts; custody found.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings requirement before custodial interrogation)
Dickerson v. United States, 530 U.S. 428 (2000) (Miranda is constitutionally based and binding)
Thompson v. Keohane, 516 U.S. 99 (1995) (custody is an objective test: would a reasonable person feel free to leave)
Berkemer v. McCarty, 468 U.S. 420 (1984) (Miranda applies when freedom of movement is curtailed to degree associated with formal arrest)
Oregon v. Mathiason, 429 U.S. 492 (1977) (presence at police station alone does not automatically create custody)
Howes v. Fields, 565 U.S. 499 (2012) (custody analysis considers whether interrogation environment created inherently coercive pressures; restraints must be assessed in context)
California v. Beheler, 463 U.S. 1121 (1983) (the ultimate inquiry is whether restraint on freedom of movement is the degree associated with an arrest)
Thomas v. State, 429 Md. 246 (Md. 2012) (Maryland application of the Miranda custody totality-of-circumstances test)