State v. Hammonds, 370 N.C. 158

On Dec. 11–12, 2012, Tae Kwon Hammonds was involuntarily committed to a hospital after an intentional overdose and was in custody under a magistrate's civil-commitment order.
Police identified Hammonds from surveillance as a suspect in an armed purse robbery and, on Dec. 12, two Monroe officers interviewed him in his ER room for about 1.5 hours without giving Miranda warnings.
Officers were in plain clothes with visible badges and firearms; they asked to sit, did not physically restrain him, did not block the door, and a hospital "sitter" was assigned outside the room.
Officers repeatedly told Hammonds he was not under arrest and had no warrants, but they did not tell him he could end questioning or ask them to leave; they told him "as soon as he talked, they could leave."
Trial court denied Hammonds's motion to suppress; the State convicted him of robbery. This Court reversed, holding the interrogation was custodial for Miranda purposes and that failure to warn required suppression and warranted vacating the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether interrogation was "custodial" for Miranda purposes	State: totality shows not custodial — no restraints, cordial tone, told not under arrest, room not locked	Hammonds: civil commitment plus officers' statements and conduct would lead a reasonable person to believe he could not terminate questioning	Court: interrogation was custodial; Miranda warnings were required
Whether failure to give Miranda warnings required suppression of statements	State: statements voluntary and admissible because no custody	Hammonds: unwarned custodial interrogation made statements inadmissible	Court: because Miranda applicable and warnings not given, statements inadmissible; suppression required
Whether any error was harmless	State: (did not attempt to show harmlessness beyond a reasonable doubt)	Hammonds: constitutional error prejudicial	Court: error was prejudicial; conviction vacated
Whether civil confinement per se negates custody	State: confinement unrelated to interrogation does not automatically create Miranda custody	Hammonds: confinement + interrogation features can create custodial pressure	Court: confinement is a relevant restriction but not dispositive; totality favored custody here because officers’ statements implied questioning would end only after he talked

Miranda v. Arizona, 384 U.S. 436 (establishing requirement of warnings for custodial interrogation)
Howes v. Fields, 565 U.S. 499 (when confinement unrelated to interrogation exists, custody inquiry requires examining all features of the interrogation)
J.D.B. v. North Carolina, 564 U.S. 261 (custody inquiry asks whether a reasonable person would feel free to terminate the interrogation)
Stansbury v. California, 511 U.S. 318 (custody depends on objective circumstances, not subjective intent)
Berkemer v. McCarty, 468 U.S. 420 (objective test for Miranda custody)
Maryland v. Shatzer, 559 U.S. 98 (freedom-of-movement test is necessary but not sufficient for custody)
Thompson v. Keohane, 516 U.S. 99 (articulating two-part custody inquiry)
State v. Buchanan, 353 N.C. 332 (N.C. formulation of custody as restraint of degree associated with formal arrest)
State v. Barden, 356 N.C. 316 (Miranda warnings required only for custodial interrogation)