State v. Cervantes, 158 A.3d 430

Victim reported a sexual assault on April 14, 2013; police later developed Marcelo Cervantes as a suspect.
Detectives, in plain clothes, located Cervantes at his workplace (an Outback restaurant) and asked the manager to invite him to speak; Cervantes agreed voluntarily.
Detectives asked Cervantes to continue the conversation in an unmarked police vehicle parked behind the restaurant; he voluntarily entered the front seat, was not handcuffed, and sat for ~15–20 minutes while questioned.
While still in the vehicle and before arriving at the station, Cervantes made incriminating oral statements admitting to sexual contact (which he characterized as consensual); later he agreed to go to the Hamden Police Department and was Mirandized there and gave a recorded statement.
Cervantes moved to suppress the statements made in the vehicle, arguing he was in custody from the moment he entered the car and should have received Miranda warnings; the trial court denied the motion and he entered a conditional nolo contendere plea under Conn. Gen. Stat. § 54-94a.
The Appellate Court affirmed, holding a reasonable person in Cervantes’s position would not have felt restrained to the degree associated with formal arrest, so Miranda warnings were not required while he was in the vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Cervantes was in custody in the police vehicle such that Miranda warnings were required	State: interrogation occurred but Cervantes was not in custody because he spoke and accompanied officers voluntarily	Cervantes: entry into the police vehicle and 15–20 minute questioning constituted custodial interrogation needing Miranda warnings	Court: Not custody — reasonable person would not feel freedom restrained to degree of formal arrest; Miranda not required in vehicle
Whether voluntary travel to station converted the encounter into custodial interrogation	State: Cervantes declined to drive, agreed to be driven; offering him a choice shows noncustodial nature	Cervantes: being driven, emotional state, and drive-by of victim’s house showed coercive environment	Court: Drive and emotional state did not transform encounter into custodial interrogation; still voluntary
Whether the denial of suppression was dispositive of the case and effect on remedy if suppression granted	State: even if suppression granted, remand for further proceedings/trial may be appropriate	Cervantes: suppression was dispositive so conviction must be vacated and prosecution barred on retrial	Court: Did not resolve the semantic dispute over “dispositive”; unnecessary because suppression denial was affirmed

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings required before custodial interrogation)
State v. Mangual, 311 Conn. 182 (Conn. 2014) (nonexclusive factors for custody analysis under Miranda)
State v. Arias, 322 Conn. 170 (Conn. 2016) (custody requires interrogation after person deprived of freedom to significant degree)