State v. Maile, 396 P.3d 1270

On Nov. 17, 2013 Chad Larsen Made was stopped at an FWP game-check station; wardens questioned him after noting the deer tag did not match the hunter.
The questioning was recorded by the reality show "Wardens." Made admitted shooting the mule deer and using others’ tags; he also admitted two additional illegal kills in Yellowstone County.
Wardens located and seized illegally harvested deer meat after obtaining consent to search Made’s freezer; Made was charged with multiple wildlife offenses.
Made moved to suppress statements, arguing he was subject to custodial interrogation and his statements were involuntary; the Justice Court denied suppression and convicted him; the district court affirmed.
The Montana Supreme Court reviewed de novo whether Made was in custody for Miranda purposes and reviewed factual findings on voluntariness for clear error.

Issue	Plaintiff's Argument (Made)	Defendant's Argument (State/FWP)	Held
Whether Made was "in custody" at the game-check station such that Miranda warnings were required	Made: questioning was custodial; he was not free to leave and thus needed Miranda warnings	State: check station stop is akin to a traffic/Terry stop (brief, public, routine); circumstances did not amount to formal arrest	Court: Not custodial—stop was public, routine, temporary; no formal arrest or restraints akin to arrest, so Miranda not required
Whether Made’s admissions were voluntary under due process (totality of circumstances)	Made: interrogation was long, aggressive, wardens threatened obstruction charges, so his will was overborne	State: questioning was public, not coercive, Made repeatedly volunteered information and extended detention; no physical or psychological coercion	Court: Admissions were voluntary under totality of circumstances; discussion of legal consequences was not coercive

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings to protect Fifth Amendment privilege)
Berkemer v. McCarty, 468 U.S. 420 (1984) (roadside/Terry stops are typically noncustodial for Miranda despite curtailment of freedom)
Thompson v. Keohane, 516 U.S. 99 (1995) (two-step objective test for custody: circumstances and whether a reasonable person would feel free to leave)
Missouri v. Seibert, 542 U.S. 600 (2004) (statements from custodial interrogation without warnings generally excluded)
Dickerson v. United States, 530 U.S. 428 (2000) (voluntariness doctrine grounded in due process independent of Miranda)
State v. Elison, 302 Mont. 228 (2000) (Montana application of Berkemer and Miranda custody analysis)
State v. Boyer, 308 Mont. 276 (2002) (upholding routine wildlife inspections and recognizing regulatory burden on hunters)