Joshua Huizar v. the State of Texas, 13-20-00181-CR

Police responded at ~9:40 p.m. to an apartment for an alleged domestic assault; victim Bertha Miranda had visible bleeding and told officers Huizar had punched her and had access to a gun upstairs.
Officer Lloyd entered with weapon drawn; Huizar came down the stairs, ignored commands, said “Shoot me,” and was handcuffed and seated on a couch within minutes.
While handcuffed, Huizar made spontaneous and responsive statements to Officer Udero and Officer Lloyd over the next ~17 minutes, admitting a firearm upstairs and giving an account that Miranda attacked him.
The trial court denied suppression of Huizar’s statements made during the first ~17 minutes, but suppressed statements made after that point; Huizar pleaded guilty reserving his right to appeal the denial as to the pre-17-minute statements.
On appeal Huizar argued the handcuffing and surrounding circumstances rendered him in custody for Miranda purposes, making his statements inadmissible; the Court of Appeals applied the objective totality-of-the-circumstances test and affirmed, holding the detention was investigative (not custodial) during the challenged period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Huizar was "in custody" for Miranda purposes when handcuffed and questioned (so his pre-arrest statements must be suppressed)	Huizar: handcuffing at gunpoint, accusatory tone, probable cause from victim’s injuries made the restraint tantamount to formal arrest.	State: officers reasonably handcuffed Huizar for officer safety and to preserve the status quo; they expressly told him he was detained, and the circumstances support an investigative detention, not custody.	Court affirmed: objective circumstances supported an investigative detention; statements during the first ~17 minutes were not custodial, so Miranda warnings were not required.

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required when a suspect is subject to custodial interrogation)
State v. Saenz, 411 S.W.3d 488 (Tex. Crim. App. 2013) (defines custody for Miranda: formal arrest or restraint similar to arrest)
Herrera v. State, 241 S.W.3d 520 (Tex. Crim. App. 2007) (defendant bears threshold burden to show custodial interrogation)
Rhodes v. State, 945 S.W.2d 115 (Tex. Crim. App. 1997) (assess officer conduct from reasonable-officer perspective; totality of circumstances governs)
State v. Sheppard, 271 S.W.3d 281 (Tex. Crim. App. 2008) (handcuffing may be reasonable during investigative detention for officer safety)
Wells v. State, 611 S.W.3d 396 (Tex. Crim. App. 2020) (standard of review: defer to trial court on historical facts; review mixed questions de novo)