United States v. Coulter, 41 F.4th 451

At 2:41 a.m. Officer Nino de Guzman stopped Braylon Ray Coulter’s van for registration/insurance issues; Guzman learned Coulter’s license was suspended and that Coulter was on parole for aggravated robbery.
During a ~15-minute roadside encounter Guzman twice asked about guns, frisked Coulter, smelled marijuana, and questioned ownership/use of the van; Coulter admitted recent marijuana use.
After Coulter hesitated and indicated he didn’t want more parole “strikes,” Guzman warned he would “detain” Coulter to prevent him from grabbing a gun, then handcuffed him for officer safety.
While handcuffed and before any Miranda warnings, Coulter told Guzman the gun was in his backpack; a second officer then recovered a .40 pistol and ~0.37 oz. marijuana and Guzman arrested Coulter.
The district court suppressed Coulter’s statements made after handcuffing for lack of Miranda warnings; the government appealed. The Fifth Circuit reversed, holding Coulter was not in Miranda custody and, alternatively, the setting was not like a station-house interrogation.

Issue	Plaintiff's Argument (U.S.)	Defendant's Argument (Coulter)	Held
Whether Coulter was "in custody" for Miranda when he made statements after handcuffing	Not custodial — a reasonable person would not feel free to leave was not met	Custodial — handcuffing and officer statements equated to formal arrest	Not custodial: a reasonable person would not have perceived restraints as equivalent to formal arrest
Whether handcuffing during a valid traffic stop automatically creates Miranda custody	No — brief handcuffing does not per se create custody	Yes — handcuffs (plus commands/threats) converted the stop into custody	No — handcuffing is relevant but not dispositive; brief handcuffing here did not compel Miranda
Whether the interrogation environment was akin to station-house coercion requiring Miranda even if restraint was sufficient	Not akin to station-house — public, brief, noncoercive traffic-stop setting	Environment was coercive (threats, backup, commands), so Miranda required	Not akin to station-house — public, brief roadside encounter did not implicate Miranda’s core concerns
Whether the district court erred in suppressing post-handcuff statements	Suppression erroneous; statements admissible	Suppression proper because Miranda warnings absent during custody	Reversed suppression; statements admissible

Miranda v. Arizona, 384 U.S. 436 (establishing Miranda rule for custodial interrogation)
Berkemer v. McCarty, 468 U.S. 420 (routine traffic stops are not custodial for Miranda purposes)
Howes v. Fields, 565 U.S. 499 (two-step custody inquiry and freedom-of-movement test)
Maryland v. Shatzer, 559 U.S. 98 (freedom-of-movement is necessary but not sufficient for Miranda custody)
United States v. Patane, 542 U.S. 630 (Miranda is prophylactic; failure to warn not always a Fifth Amendment violation)
New York v. Quarles, 467 U.S. 649 (public-safety exception to Miranda)
United States v. Wright, 777 F.3d 769 (5th Cir. factors for custody analysis)
United States v. Ortiz, 781 F.3d 221 (brief interviews during stops suggest noncustody)
United States v. Bengivenga, 845 F.2d 593 (5th Cir. en banc formulation of custody standard)
United States v. Bautista, 684 F.2d 1286 (9th Cir.: handcuffing does not necessarily dictate custody)