State of Washington v. Kenneth Leroy Stephens, 36542-5

Stan’s Merry Mart reported to 911 that a man who had previously stolen cameras (described by clothing and approximate age) was leaving on a bicycle; employees wanted charges for past thefts.
Officer Gonzalez located Kenneth Stephens riding a bike matching the clothing description (Stephens was older than the caller’s age estimate) and recognized him from prior contacts.
Gonzalez told Stephens he could not leave, handcuffed him, and read Miranda warnings from a card; Gonzalez then questioned Stephens about the thefts.
Stephens denied initially, then admitted stealing and selling the cameras; after the admission Gonzalez told Stephens he was under arrest, searched him, and found methamphetamine and a meth pipe.
Stephens moved to suppress the confession and the meth, arguing he was under arrest (thus requiring probable cause) when handcuffed and Mirandized; the trial court denied suppression, and Stephens was convicted of possession of meth.
The Court of Appeals held Gonzalez’s handcuffing and Mirandizing constituted an arrest under an objective reasonable-person test, suppressed the meth evidence, and reversed/dismissed the possession conviction.

Issue	Plaintiff's Argument (Stephens)	Defendant's Argument (State)	Held
Whether Gonzalez’s initial handcuffing and Mirandizing constituted an arrest requiring probable cause	Handcuffing + Miranda before questioning created a custodial arrest (not an investigatory stop); no probable cause existed then, so evidence must be suppressed	No arrest occurred until Gonzalez announced the arrest after the confession; handcuffing/Mirandizing were precautionary and did not convert the stop into an arrest	Court held a reasonable person would have felt under arrest when handcuffed and Mirandized; this was an arrest requiring probable cause

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigatory stop and reasonable suspicion standard)
Berkemer v. McCarty, 468 U.S. 420 (1984) (custody test and Miranda context; objective custody inquiry)
State v. Rupe, 101 Wn.2d 664 (1984) (definition of arrest; free-to-leave and future restraint factors)
State v. Acrey, 148 Wn.2d 738 (2003) (Terry stop principles applied under Washington law)
State v. Reichenbach, 153 Wn.2d 126 (2004) (objective test for custody/arrest under state law)
State v. Flores, 186 Wn.2d 506 (2016) (warrantless seizures and arrest vs. investigatory stop distinctions)
State v. Ortega, 177 Wn.2d 116 (2013) (arrest occurs when officer manifests intent and seizes; reasonable-person standard)