State v. Ames, 155 A.3d 881

Ames, jailed on an unrelated probation-violation arrest, was interviewed in the county jail visitation room by two plainclothes, unarmed detectives about a reported restaurant burglary; the interview was recorded.
The detectives told Ames the questioning was voluntary, that he could stop and return to his cell at any time, and that the subject did not concern his probation matter.
Ames denied involvement for about fifteen minutes, then confessed after detectives suggested cooperation could affect outcomes; no Miranda warnings were given.
Ames moved to suppress the statements as the product of custodial interrogation; the suppression court denied the motion.
Ames entered a conditional guilty plea reserving the right to appeal the suppression ruling; the court affirmed the denial on appeal and affirmed the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ames was "in custody" for Miranda purposes during the jail interview	Ames: incarceration + detectives' questioning created custodial coercion so Miranda warnings were required	State: interview circumstances (plainclothes, unarmed officers; room layout; told free to leave; brief, conversational interview) show no custody	Court: Not custodial under totality; Miranda not required

Howes v. Fields, 565 U.S. 499 (prisoner interrogation not categorically custodial; totality test applies)
State v. Ntim, 76 A.3d 370 (Me. 2013) (standard of review for suppression findings)
State v. Bryant, 97 A.3d 595 (Me. 2014) (factors for custodial interrogation analysis)
State v. Kittredge, 97 A.3d 106 (Me. 2014) (consideration of officer appearance, number present, and interrogation length)