People v. Hughes, 252 P.3d 1118

Two interlocutory appeals challenge trial-court suppression orders based on Miranda custody determinations.
In Hughes, officers interviewed the victim at a residence while defendant approached and waited; no physical coercion or arrest occurred before questioning.
The trial court suppressed Hughes statements, relying on a custody finding based on the belief that a reasonable person would not be free to leave and on the officers’ subjective intent to arrest.
In Meza-Reyes, stop for running a red light led to questions about identity; the defendant invoked counsel and was subsequently arrested; trial court suppressed subsequent questions as impermissible without further advisement.
Colorado Supreme Court reviews de novo whether the custodial-interrogation standard under Miranda was properly applied, distinguishing it from Fourth Amendment seizure.
The Court holds the trial courts erred by applying the wrong standard and by relying on subjective officer beliefs; suppression orders are reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miranda custody standard was correctly applied	People contend the trial courts used the wrong standard conflating Fourth Amendment seizure with Miranda custody.	Hughes/Meza-Reyes contend custodial atmosphere existed or would be perceived as custodial under Miranda.	Trial courts applied the wrong standard; custody under Miranda was not established.
Whether investigatory stops implicate Miranda custody	People argue stops do not automatically trigger Miranda custody analysis.	Meza-Reyes contends the stop and questioning before arrest could be custody under Miranda.	Investigatory stops do not necessarily implicate Miranda custody; custody requires a formal arrest-like deprivation.
Whether officer subjective beliefs may determine custody	People argue officers’ beliefs about custody can inform the custody determination.	Defendants contend subjective views are relevant to understanding the encounter.	Custody is objective; unarticulated officer thoughts cannot govern the custody ruling.

Brendlin v. California, 551 U.S. 249 (U.S. 2007) (seizure considerations under Fourth Amendment separate from Miranda custody)
Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (interrogation and its scope under Miranda)
Stansbury v. California, 511 U.S. 318 (U.S. 1994) (custody assessment is objective, not based on internal beliefs)
Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (distinction between on-scene questioning and formal arrest)
Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (limitations on interrogation in custodial settings)
People v. Hankins, 201 P.3d 1215 (Colo. 2009) (objective custody standard in Colorado)
People v. Matheny, 46 P.3d 453 (Colo. 2002) (custody determination guided by totality of circumstances)
People v. Breidenbach, 875 P.2d 879 (Colo. 1994) (Fourth Amendment seizure vs. Miranda custody distinction)
People v. Cowart, 244 P.3d 1199 (Colo. 2010) (custody test is objective; subjective police beliefs are not dispositive)
People v. Ortega, 34 P.3d 986 (Colo. 2001) (standard for reviewing suppression orders)
People v. Humphrey, 132 P.3d 352 (Colo. 2006) (requirement to apply correct legal standard to suppression)