State v. Maciel, 240 Ariz. 46

Background

Police responded to a motorist’s report of a person (Maciel) sitting by a vacant church building with a broken window and missing boarding.
Officer Huntley approached Maciel, obtained ID, conducted a pat-down, and asked investigatory questions; Maciel was briefly placed in the patrol car and then asked to sit on a curb while officers checked the building.
While officers inspected the perimeter, the church pastor arrived and said the window had been boarded three days earlier and would pursue charges if a suspect was identified.
After the pastor’s statement, Huntley returned and Maciel admitted removing the board and entering the building; Maciel was then arrested, Mirandized, and repeated the admission.
Maciel moved to suppress his pre-arrest statements as elicited in custody without Miranda warnings; the trial court denied suppression, a split court of appeals affirmed, and the Arizona Supreme Court granted review.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Maciel was "in custody" for Miranda when questioned curbside	Maciel argued he was not free to leave and thus in custody; statements inadmissible without Miranda	State argued the encounter was an investigative detention (Terry stop), not custodial interrogation	Court held Maciel was not in Miranda custody; statements admissible
Whether restraint on freedom of movement alone establishes Miranda custody	Maciel contended objective restraint (sitting in car, watched by officers) made detention custodial	State relied on precedent distinguishing Terry stops and public questioning from station-house coercion	Court held restraint alone insufficient; must also show environment with coercive pressures akin to station-house interrogation
Whether public, brief, visible questioning converted the stop into coercive custodial interrogation	Maciel argued continued supervision, multiple officers, and questioning created coercive pressure	State emphasized public location, short duration (<1 hour), modest officer presence, and diligent investigation	Court found public setting, lack of isolation, brief duration, and police diligence militated against coercion
Whether post-arrest statements should be suppressed because initial pre-arrest statements were obtained in violation of Miranda	Maciel argued later statements tainted and should be suppressed under Seibert/Elstad principles	State did not contest admissibility of post-arrest statements once custodial warnings were given	Court declined to reach Seibert/Elstad issue because pre-arrest statements were admissible (no Miranda violation)

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes custodial interrogation warnings requirement)
Howes v. Fields, 565 U.S. 499 (2012) (custody analysis requires coercive environment akin to station-house questioning)
Maryland v. Shatzer, 559 U.S. 98 (2010) (restraint alone does not equal Miranda custody; traffic/Terry stops distinguished)
Berkemer v. McCarty, 468 U.S. 420 (1984) (public investigative stops generally not custodial; public exposure reduces coercion)
Terry v. Ohio, 392 U.S. 1 (1968) (authorizes brief investigative detentions)
United States v. Sharpe, 470 U.S. 675 (1985) (duration and police diligence determine when investigative detention becomes unreasonable)
Missouri v. Seibert, 542 U.S. 600 (2004) (rule on admissibility of post-warning statements after unwarned interrogation)
Oregon v. Elstad, 470 U.S. 298 (1985) (confessions given post-warning after earlier unwarned admission may be admissible under certain conditions)
State v. Cruz-Mata, 138 Ariz. 370 (1983) (Arizona precedent on Miranda custody: formal arrest or restraint test)
State v. Boteo-Flores, 230 Ariz. 105 (2012) (investigative detention duration and reasonableness analysis)