City of Missoula v. Kroschel, 419 P.3d 1208

At a University of Montana football game Officer Parsons (UM campus police) observed two young women appearing unsteady, smelled alcohol, and asked for ID to investigate a possible minor-in-possession (MIP).
Kroschel gave a misspelled name and a false date of birth indicating she was 21; database (UM and CJIN) checks returned no record for the provided name/DOB.
Parsons asked multiple times for Kroschel's true name/DOB, then told her she was obstructing the investigation, threatened a jailable charge, grabbed her arm, and escorted her downstairs toward the station.
Detective Croft joined, Parsons sent Kroschel's friend away, and the officers brought Kroschel into a secluded closed room for repeated, isolating questioning; Kroschel ultimately gave her true name/DOB and was cited for MIP and obstruction.
Kroschel moved to suppress evidence (age, DOB, false statements) arguing Fourth Amendment unlawful prolonged stop and Fifth Amendment Miranda violation; municipal and district courts denied the motion and she appealed to the Montana Supreme Court.

Issue	Kroschel's Argument	State's Argument	Held
Whether officers had particularized suspicion to prolong the Terry stop after database checks returned no record	Negative database returns did not create additional articulable suspicion; stop should have ended (citing Driscoll/Bauer)	Officer Parsons had additional facts (observations plus experience that negative returns often indicate false identity) supporting continued detention to investigate MIP and obstructing officer	Court: Initially stop was lawful and officers had sufficient particularized suspicion to continue investigation after negative database returns (affirmed in part)
Whether questioning ripened into custodial interrogation triggering Miranda warnings	Repeated, secluded, coercive questioning after threats and being taken to closed room was custodial; name/DOB were testimonial and incriminating because age is an element of MIP	Information sought was basic biographical data; booking/administrative or routine identification questions need not be Mirandized (Muniz/Byers/Hiibel analogies)	Court: Detention and repeated secluded questioning did ripen into custodial interrogation; requested name/DOB were directly incriminating here and admissible only if Mirandized — Miranda violation (suppression required)

Terry v. Ohio, 392 U.S. 1 (1968) (establishes temporary investigative "Terry" stop standard)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required before custodial interrogation)
Hiibel v. Sixth Judicial Dist. Court, 542 U.S. 177 (2004) (permissibility of identity requests during Terry stop; Fifth Amendment limits)
Pennsylvania v. Muniz, 496 U.S. 582 (1990) (booking-question exception for routine biographical data)
California v. Byers, 402 U.S. 424 (1971) (statutory self-identification not per se Fifth Amendment violation where regulatory)
State v. Driscoll, 369 Mont. 270, 303 P.3d 788 (2013) (Montana suppression where officers lacked particularized suspicion to prolong stop after identification given)
State v. Bauer, 307 Mont. 105, 36 P.3d 892 (2001) (Montana: generally unreasonable to arrest/detain for non-jailable offense absent special circumstances)
United States v. Sharpe, 470 U.S. 675 (1985) (duration of stop must be reasonably diligent to confirm or dispel suspicion)