State v. Mangual, 311 Conn. 182

Mangual was convicted of possession with intent to sell narcotics and sentenced to eight years after a warrant-based search of her New Britain apartment uncovered heroin in a hairspray can.
The Appellate Court rejected Mangual’s claim that statements made to an officer during the search were obtained in violation of Miranda, ruling she was not in custody for Miranda purposes.
This Court granted certification to review whether Mangual was in custody for Miranda when questioned during the execution of the search warrant.
During the search, seven officers entered the four-room apartment, detained Mangual and her daughters in the living room, and maintained control over the scene and occupants.
Hicks questioned Mangual without Miranda warnings; Mangual stated there were drugs in the bedroom, leading officers to the hairspray can containing heroin.
The Court held that Mangual was in custody for Miranda purposes and that the Miranda violation was not harmless beyond a reasonable doubt, reversing the Appellate Court and ordering a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mangual was in custody for Miranda purposes when questioned	Mangual was in custody due to police domination and restraint during the search.	Mangual was not in custody; questioning occurred in her home and under a noncustodial Terry-like framework.	Yes; Mangual was in custody for Miranda purposes.
Whether the Miranda violation was harmless beyond a reasonable doubt	Other independent evidence established guilt; Miranda error was harmless.	Statement evidence was the only direct knowledge linking Mangual to the heroin; error was not harmless.	No; the error was not harmless beyond a reasonable doubt.
Remedy for the Miranda violation	Harmless error doctrine supports affirming if guilt is proven without the statements.	New trial warranted due to Miranda violation affecting the outcome.	Reverse and remand for a new trial.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (mandatory warnings protect against custodial interrogation)
Oregon v. Mathiason, 429 U.S. 492 (U.S. 1977) (warnings not required for noncustodial questioning)
Thompson v. Keohane, 516 U.S. 99 (U.S. 1995) (ultimate custody determination hinges on whether freedom to leave was curtailed to arrest-like degree)
Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (typical traffic stops are noncustodial; custody analysis requires more restraint than mere seizure)
Howes v. Fields, 132 S. Ct. 1193 (U.S. 2012) (custody is an objective, reasonable-person inquiry about restraint and coercion)
J. D. B. v. North Carolina, 131 S. Ct. 2394 (U.S. 2011) (age and subjective perceptions relevant to custody under the totality of circumstances)
Maryland v. Shatzer, 559 U.S. 98 (U.S. 2010) (clarifies that custody analysis is not merely about freedom of movement)