State v. Stricklin, 558 S.W.3d 54

Victim, born 2010, suffered a genital injury January 28, 2013; Stricklin (Mother's boyfriend) spent the prior night at the home.
Police asked Stricklin to come to the Desloge station; he was patted down in the lobby, told he was not under arrest, and interviewed in an audio-recorded session lasting just over an hour.
During the interview officers became accusatory; about 18 minutes in Officer Judge said he would step out and: "when I come back in, if you haven't settled this up... you're probably going. You're going in cuffs." Stricklin replied, "I want a lawyer. Right now."
Officer Judge left and closed the door; Officer Minze continued, told Stricklin he would likely go to jail, and repeatedly declined to promise he could get time to arrange affairs. Under that pressure Stricklin ultimately made oral admissions on the recording and wrote a post-interview letter admitting an accidental penetration.
Stricklin was arrested after the interview and never received Miranda warnings. He moved to suppress the oral and written statements; the trial court denied suppression, he was convicted of first-degree statutory sodomy and sentenced to 30 years.
On appeal the Missouri Court of Appeals held the interview became custodial when Officer Judge threatened custody and left the room, officers never Mirandized Stricklin, and suppressed all statements made after that point; the conviction was reversed and remanded.

Issue	Plaintiff's Argument (Stricklin)	Defendant's Argument (State)	Held
Whether the station-house interview became custodial, triggering Miranda	Interview became custodial once officers accused him and Judge said he would leave and "you're going in cuffs," after which Stricklin asked for a lawyer; no Miranda warnings were given	Interview was voluntary and non-custodial: Stricklin came voluntarily, was told he was not under arrest, was not physically restrained, and the interrogation tone was not coercive	Held custodial from the moment Judge threatened "you're going in cuffs" and left; Miranda warnings required but not given, so statements after that point suppressed
Whether statements made after Judge left (including written letter) are admissible	Post-threat oral admissions and the written letter were product of custodial interrogation and must be suppressed	The State argued totality of circumstances did not show custody so statements admissible	Held inadmissible: all statements after Judge's departure suppressed; pre-departure portion of recording not suppressed
Whether pre-departure recorded statements can be used	N/A (implicit)	N/A	Held pre-departure portion was not custodial and is not subject to Miranda suppression
Whether suppressed statements could be used for impeachment or other non-Miranda purposes	N/A	N/A	Court noted Miranda-barred statements may still be used to impeach if voluntary; remanded for further proceedings consistent with opinion

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required before custodial interrogation)
Thompson v. Keohane, 516 U.S. 99 (custody inquiry: objective reasonable-person test)
Howes v. Fields, 565 U.S. 499 (station-house questioning not always custodial; totality of circumstances)
State v. Holman, 502 S.W.3d 621 (Miranda applies when suspect is subject to custodial interrogation)
State v. Brooks, 185 S.W.3d 265 (police control of interview can convert voluntary interview to custodial)
State v. Quick, 334 S.W.3d 603 (custody analysis focuses on whether a reasonable person would feel free to terminate questioning)
State v. Hill, 247 S.W.3d 34 (contrast case finding no custody where suspect told he was not under arrest and could leave)