Thomas v. State, 429 Md. 246

Thomas was invited to the police station after his wife told authorities about alleged sexual abuse of their daughter and Thomas met with two detectives for about 90 minutes, during which he confessed to touching and having intercourse with his daughter.
Prior to questioning, the circuit court suppressed Thomas’s statements, ruling Miranda warnings were required, a ruling the Court of Special Appeals reversed, and the Maryland Court granted certiorari to address custody questions.
Key pre-interview facts include that Thomas drove himself to the station, was told he was not under arrest, and that the interrogation occurred in a small room with a door described as unlocked but not left open, and two plain-clothes, unarmed detectives conducted the interview.
During the interview, detectives confronted Thomas with allegations from his wife and daughter, and the atmosphere was described as non-confrontational but accusatory as the questioning progressed and details were elicited.
Thomas was not arrested at the outset; he was arrested about 20 minutes after the interview ended, following his written confession, with the arrest considered in the custody analysis but not dispositive on its own.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether belief of probable arrest renders a person custody for Miranda	Thomas argues that knowing police had probable cause before questioning makes him in custody.	State contends custody hinges on objective circumstances, not subjective beliefs of probable arrest.	Probable-cause belief alone is not custody.
Whether pre-interview awareness of a pending investigation supports custody	Thomas contends knowledge of investigation and evidence supports custody from arrival.	State argues custody requires objective, situational factors, not mere awareness of investigation.	Awareness of investigation alone does not establish custody.
Whether the totality of circumstances during interrogation established custody	Thomas asserts factors such as room with toys, door unlocked, two detectives, and lack of free-to-leave signals indicate custody.	State maintains the factors do not compel a custody finding; defendant was free to leave despite some coercive elements.	Thomas was not in custody; the interrogation was non-custodial under totality.
Whether a confession changes the custody status of an ongoing interrogation	Thomas argues that admitting to serious crimes while under interrogation transforms the setting into custodial.	State argues that admission of guilt does not automatically convert non-custodial questioning into custodial interrogation.	A confession does not automatically render the interrogation custodial.

Miranda v. Arizona, 384 U.S. 436 (Supreme Court 1966) (establishes the need for warnings before custodial interrogation)
Stansbury v. California, 511 U.S. 318 (Supreme Court 1994) (custody determination is objective, not subjective)
Berkemer v. McCarty, 468 U.S. 420 (Supreme Court 1984) (police suspicions do not alone trigger custody for Miranda)
Owens v. State, 399 Md. 388 (Md. 2007) (roadmap factors for Maryland custody analysis; pre- and post-interview circumstances)
Whitfield v. State, 287 Md. 124 (Md. 1980) (factors including location, duration, number of officers, and restraint)
State v. Rucker, 374 Md. 199 (Md. 2003) (custody determination and the role of surrounding circumstances)