Fredrick E. Morton v. United States, 125 A.3d 683

Officers observed Morton fleeing when approached in a high-drug-activity area; one officer saw him throw a small object later recovered as a wallet containing another person’s ID.
Morton was pursued about 200 yards, stopped, placed in handcuffs for officer/suspect safety, and told he was not under arrest.
While handcuffed and detained on the street, officers asked accusatory questions (e.g., why he ran; what about the wallet); Morton gave incriminating responses before formal arrest.
After a dispatcher name-check, officers discovered an unrelated warrant, formally arrested Morton, and recovered keys and other items linking him to a recent burglary and a stolen vehicle.
Morton moved to suppress his pre-arrest statements as taken in violation of Miranda; the trial court denied the motion and the statements were used at trial. He was convicted on two receiving-stolen-property counts and appealed.
The D.C. Court of Appeals reversed, holding that under the totality of circumstances Morton was in Miranda custody when questioned and his unwarned statements should have been suppressed.

Issue	Morton’s Argument	Government’s Argument	Held
Whether Morton was in Miranda custody when questioned while handcuffed on the street	He was in custody: chased, apprehended, handcuffed, and questioned accusatorily, so Miranda warnings were required	Not custody: officers said he was not under arrest; questioning was investigatory, brief, public, two officers, no weapons displayed	Reversed: under the totality of circumstances a reasonable person would not feel free to leave; handcuffing + accusatory questioning equated to custody for Miranda
Proper objective baseline for custody (reasonable person standard)	Miranda analysis should treat the detainee as a reasonable person in Morton’s position (taking into account facts known/conveyed to him)	Government favored a baseline where officer statements that suspect was not under arrest and public setting weigh against custody	Concurrence clarified: reasonable-person baseline is ordinarily an "innocent" person, but if officers convey by word or deed their knowledge/suspicion of guilt, the detainee’s awareness of that may be attributed in the custody analysis

Thompson v. Keohane, 516 U.S. 99 (establishes totality-of-circumstances and objective test for Miranda custody)
Berkemer v. McCarty, 468 U.S. 420 (Miranda custody assessed by how a reasonable person in suspect's position would perceive freedom to leave)
Stansbury v. California, 511 U.S. 318 (officer’s beliefs matter only if conveyed to the detainee and would affect how a reasonable person gauges freedom to leave)
J.D.B. v. North Carolina, 564 U.S. 261 (objective custody test excludes most idiosyncratic traits; courts may account for certain characteristics like age)
In re I.J., 906 A.2d 249 (D.C. 2006) (distinguishes Fourth Amendment seizure from Fifth Amendment custody; custody may exist absent formal arrest)
White v. United States, 68 A.3d 271 (D.C. 2013) (handcuffing is a strong indicator of Miranda custody; no single factor dispositive)
Al-Mahdi v. United States, 867 A.2d 1011 (D.C. 2005) (handcuffing as hallmark of formal arrest in custody analysis)
New York v. Quarles, 467 U.S. 649 (defendant chased and restrained in handcuffs was in custody)