People v. Elliott, 494 Mich. 292

Defendant was paroled after an earlier robbery conviction and was later arrested on a warrant for absconding; while jailed, police questioned him about a separate gas‑station robbery, read Miranda warnings, and he requested counsel.
Three days later a substitute parole officer, Cheryl Evans, visited the jail to serve an amended parole‑violation notice (including the robbery) and asked for a statement; defendant made inculpatory remarks in a 15–25 minute interview in the jail library.
Evans did not give Miranda warnings and did not recall being told that police had been told the defendant requested counsel; she later testified at trial about his admissions.
At trial the court admitted Evans’s testimony; defendant was convicted of armed robbery and sentenced; the Court of Appeals reversed holding Miranda/Edwards barred admission because a parole officer is a law‑enforcement officer and the interview was custodial.
The Michigan Supreme Court granted review and reversed the Court of Appeals, holding that Miranda/Edwards protections apply only when there is custodial interrogation and that Evans’s interview was not custodial, so no suppression was required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Evans’s questioning constituted "custodial interrogation" for Miranda purposes	Evans (prosecution) argued the jail interview was noncustodial under Fields; Miranda warnings were not required	Elliott argued the parole‑officer interrogation was custodial and thus subject to Miranda	Court held interview was noncustodial (short duration, noncoercive, parole officer not exercising police station‑house coercion)
Whether Edwards protection (post‑invocation prohibition on further interrogation absent counsel) barred Evans’s questioning	Prosecution: Edwards inapplicable because there was no custodial interrogation by Evans even though defendant earlier invoked counsel	Elliott: Edwards remained in effect because the custodial environment from police interrogation continued and defendant did not initiate the subsequent conversation	Court held Edwards did not apply because Edwards protects only against further custodial interrogation; no custodial interrogation occurred with Evans
Whether parole officer status alone triggers Miranda/Edwards	Court of Appeals: parole officers are law‑enforcement officers for Miranda, so their questioning can trigger Miranda/Edwards	Prosecution: being a law‑enforcement officer is not sufficient; the custody inquiry is dispositive	Court held law‑enforcement status alone is insufficient; custodial interrogation is the necessary condition for Miranda/Edwards to apply

Miranda v. Arizona, 384 U.S. 436 (establishing warnings required before custodial interrogation)
Edwards v. Arizona, 451 U.S. 477 (post‑invocation rule barring further police‑initiated custodial interrogation absent counsel)
Howes v. Fields, 565 U.S. 499 (custody inquiry for prisoners; freedom‑of‑movement test and coercion focus)
Maryland v. Shatzer, 559 U.S. 98 (discussing Edwards framework and custody continuity)
Minnesota v. Murphy, 465 U.S. 420 (probation officer interviews are not per se custodial; intent/knowledge of officer irrelevant)
Estelle v. Smith, 451 U.S. 454 (pretrial psychiatric examination and use of statements; custodial concerns in nonpolice interviews)