Com. v. Blankenship, V., 301 MDA 2016

On Sept. 3, 2014, Vandy Blankenship called 911 to report a murder; police responded and spoke with him at the scene.
Officers asked Blankenship to accompany them to the police station; he consented, was searched for officer safety (no weapons), was not handcuffed, and was not arrested at that time.
At the station he was interviewed in the media room for ~30–60 minutes; Detective Mackley later returned and asked Blankenship to go upstairs to the detective division, which Blankenship agreed to.
Blankenship was interviewed from about 4:00 A.M. to 8:30 A.M. (general interview) without Miranda warnings, then given a formal Q&A from ~8:40 A.M.–12:30 P.M.; after the interview he consented to a buccal swab.
He was formally arrested on a York County warrant at 12:45 P.M., Mirandized at 12:51 P.M., and additional questioning continued into the evening.
Blankenship was convicted of first-degree murder after trial and appealed, arguing the trial court erred in denying his motion to suppress statements/evidence obtained while allegedly in custody without Miranda warnings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Blankenship was in custody at ~4:10 A.M., making statements subject to suppression as fruit of an illegal arrest	Blankenship: police effectively detained and restricted his freedom when they moved him to the detective division and questioned him after ~1 hour, without probable cause to arrest	Commonwealth: Blankenship consented to go to the detectives’ office, was not restrained or handcuffed, was cooperative, and was not under arrest at that time	Court: Not custody at 4:10 A.M.; no illegal arrest suppression basis; motion to suppress denied
Whether police conducted a custodial interrogation at ~4:10 A.M. without Miranda warnings, requiring suppression of statements	Blankenship: the questioning at the detective division was custodial interrogation requiring Miranda warnings; absence of warnings mandates suppression	Commonwealth: interrogation was noncustodial (objective test), so Miranda warnings were not required; Blankenship voluntarily participated and never asked for counsel or to stop	Court: Interrogation was noncustodial under totality of circumstances; Miranda not required; suppression properly denied

Commonwealth v. Ransom, 103 A.3d 73 (Pa. Super. 2014) (standard of review for suppression rulings and appellate scope)
Commonwealth v. Boczkowski, 846 A.2d 75 (Pa. 2004) (custody defined by restraint on freedom of movement and reasonable belief of restriction)
Commonwealth v. Mannion, 725 A.2d 196 (Pa. Super. 1999) (factors for custody analysis: basis, length, location, transport, restraints, force, investigative methods)