State of Maine v. Moses King, 136 A.3d 366

On Dec. 27, 2013 Portland officers stopped Moses King after a victim identified his vehicle and gave its plate to a South Portland detective investigating an earlier assault.
Officers took King’s license and registration, kept blue lights activated, and asked him to wait for the South Portland detective; the documents were not returned during the wait.
The detective arrived ~15+ minutes later, asked King to exit his vehicle, then interrogated him aggressively, made accusatory and deceptive statements (including false statements about DNA), and directed officers to handcuff King during the questioning.
King made incriminating statements before being formally arrested or given full Miranda warnings; after handcuffing the detective paraphrased Miranda rights and continued questioning.
King moved to suppress his pre-arrest statements; the suppression court denied suppression of statements made before formal arrest. A jury convicted King of criminal threatening based in part on the videotaped pre-arrest statements.
The Maine Supreme Judicial Court reviewed the suppression ruling de novo and concluded King was in custody when he made pre-arrest statements; those statements were inadmissible, so the conviction and part of the suppression order were vacated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, articulable suspicion to stop King’s vehicle	State: victim’s identification and plate info gave reasonable suspicion	King: stop not supported by reliable suspicion	Held: stop was supported by reasonable, articulable suspicion
Whether King’s statements were voluntary	State: statements were voluntary under totality of circumstances	King: statements coerced or involuntary	Held: statements were voluntary
Whether King was in custody (Miranda) when he made pre-arrest statements	State: not in custody until formal arrest/handcuffing	King: detention became custodial before formal arrest (due to retained ID, flashing lights, multiple officers, accusatory/deceptive questioning)	Held: King was in custody when interrogated pre-arrest; Miranda warnings required and statements inadmissible

State v. Kittredge, 97 A.3d 106 (Me. 2014) (State bears burden to prove admissibility of statements and custody is a mixed question reviewed de novo)
State v. Prescott, 48 A.3d 218 (Me. 2012) (custody inquiry considers objective factors including retention of ID and duration)
State v. Dion, 928 A.2d 746 (Me. 2007) (lists non-exhaustive factors for custody analysis)
State v. McDonald, 6 A.3d 283 (Me. 2010) (reliability of witness ID can support reasonable suspicion)
State v. Lavoie, 1 A.3d 408 (Me. 2010) (voluntariness analyzed under totality of circumstances)
Florida v. Royer, 460 U.S. 491 (U.S. 1983) (length of detention relevant to whether investigatory stop became custodial)