People of Michigan v. John Edward Barritt, 333206

Defendant John Barritt was brought to a police station and questioned by two armed Calhoun County deputies about the disappearance of Amy Wienski; questioning began around 7:40 p.m. and lasted about 90 minutes.
Barritt arrived at his home to find deputies executing a search warrant; he was escorted to and seated in the back of a marked police car and driven to the station during nonworking hours.
He was questioned in a closed office in a locked building, was not told he could leave or terminate the interview, and was arrested at the conclusion of the interview without confessing.
Deputies used accusatory, confrontational questioning challenging Barritt’s denials; officers had already considered Barritt the prime suspect when applying for a search warrant.
The court’s analysis centers on whether Barritt was "in custody" for Miranda purposes during the stationhouse questioning.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Barritt in custody during the questioning (triggering Miranda warnings)?	Police argue the totality of circumstances did not amount to custody.	Barritt contends he was effectively restrained and not free to leave, so Miranda warnings were required.	Court (concurring opinion) held Barritt was in custody during questioning.
Do Howes factors (location, duration, statements, restraints, release) indicate custody?	Police minimize individual factors (e.g., no handcuffs, voluntary ride).	Barritt emphasizes station setting, accusatory tone, transport in marked car, lack of being told he could leave, and post-interview arrest.	Applying Howes factors, the concurring judge found they weigh heavily for custody.
Does absence of explicit advisement that suspect may leave weigh toward custody?	Officers may argue absence is neutral if suspect not affirmatively restrained.	Barritt argues never told he could leave and deputies would not have permitted him to do so.	Court treats failure to inform as significant evidence supporting custody.
Does post-interview arrest negate a finding that interview was noncustodial?	Police could argue arrest after interview confirms noncustodial status during it.	Barritt argues arrest after interview supports that he was effectively in custody throughout.	Court views arrest at conclusion (without confession) as consistent with custody during questioning.

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required when freedom of action is significantly curtailed)
Dickerson v. United States, 530 U.S. 428 (Miranda safeguards address coercion inherent in custodial interrogation)
Howes v. Fields, 565 U.S. 499 (relevant custody factors: location, duration, statements, restraints, release)
Stansbury v. California, 511 U.S. 318 (custody determined by objective totality-of-circumstances)
Yarborough v. Alvarado, 541 U.S. 652 (failure to tell a suspect he can leave supports custody finding)
Berkemer v. McCarty, 468 U.S. 420 (public or home questioning weighs against custody)
Beckwith v. United States, 425 U.S. 341 (stationhouse environment often indicates police-dominated atmosphere)