People v. Davidson, 164 Cal. Rptr. 3d 798

On April 22, 2012, a homeowner reported a new Suzuki motorcycle stolen; around 9:45 a.m. a witness saw defendant Andrew Davidson pushing that motorcycle and called 911.
Officer Coulter arrived, observed jumper wires hanging from the ignition and defendant attempt to conceal the bike; he handcuffed defendant for officer safety, told him he was being detained to investigate a possible theft, and asked one question: “Is this your vehicle?”
Defendant answered that he found the motorcycle in nearby bushes; he was then arrested, a glass meth pipe was found on his person, and the owner identified the bike as stolen.
At trial defendant argued he innocently found the motorcycle; the prosecution introduced rebuttal evidence of a prior 2010 vehicle theft where the ignition had been punched out and a flat-head screwdriver was present.
The trial court admitted defendant’s pre-arrest answer without Miranda warnings (finding no custodial interrogation) and admitted the prior theft under Evidence Code §1101(b); the jury convicted defendant of vehicle theft and possession of a meth pipe.
On appeal the court reviewed (1) whether the on-scene, post-handcuffing question required Miranda warnings, and (2) whether the prior car-theft evidence was admissible and not unduly prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a single on-scene question after handcuffing was a custodial interrogation requiring Miranda warnings	The question was investigatory to confirm ownership, not custodial interrogation; it was brief, public, and aimed to dispel suspicion	Handcuffing and questioning transformed the encounter into custodial interrogation, so Miranda warnings were required	Not custodial for Miranda purposes; the brief on-scene question was admissible
Whether prior 2010 car theft evidence was admissible under Evid. Code §1101(b) and not unduly prejudicial	The prior theft shows knowledge, intent, and common plan (similar modus operandi) and probative value outweighed prejudice	The evidence was propensity-based and more prejudicial than probative	Admissible for knowledge/intent/common plan; jury instructions limited use and the admission was not an abuse of discretion

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings)
People v. Manis, 268 Cal.App.2d 653 (1969) (permitting on-the-scene questioning during temporary detention)
People v. Leonard, 40 Cal.4th 1370 (2007) (standard for reviewing custody for Miranda)
People v. Farnam, 28 Cal.4th 107 (2002) (investigatory questions to confirm or dispel suspicion are not custodial interrogation)
Berkemer v. McCarty, 468 U.S. 420 (1984) (answers to investigatory roadside questions admissible without Miranda)
Culombe v. Connecticut, 367 U.S. 568 (1961) (quoting rationale for questioning suspects to obtain information)
People v. Pilster, 138 Cal.App.4th 1393 (2006) (handcuffing during brief detention not dispositive of custody)
Orozco v. Texas, 394 U.S. 324 (1969) (place and setting are factors in custody analysis)
People v. Clair, 2 Cal.4th 629 (1992) (totality of circumstances test for custody)
People v. Ewoldt, 7 Cal.4th 380 (1994) (standards for admitting other-crimes evidence)
People v. McDermott, 28 Cal.4th 946 (2002) (presumption that jury follows limiting instruction)