Cite as: 507 U. S. 680 (1993)
Opinion of O'Connor, J.
Even assuming that many Miranda claims could "simply be recast" as voluntariness claims, it does not follow that barring Miranda's prophylactic rule from habeas would unduly complicate their resolution. The Court labels Miranda a "bright-line (or, at least, brighter-line) rul[e]" and involuntariness an "exhaustive totality-of-circumstances approach," ante, at 694, but surely those labels overstate the differences. Miranda, for all its alleged brightness, is not without its difficulties; and voluntariness is not without its strengths. Justice White so observed in his Miranda dissent, noting that the Court could not claim that
"judicial time and effort . . . will be conserved because of the ease of application of the [Miranda] rule. [Miranda] leaves open such questions as whether the accused was in custody, whether his statements were spontaneous or the product of interrogation, whether the accused has effectively waived his rights, . . . all of which are certain to prove productive of uncertainty during investigation and litigation during prosecution." Miranda, supra, at 544-545.
Experience has proved Justice White�s prediction correct. Miranda creates as many close questions as it resolves. The task of determining whether a defendant is in "custody" has proved to be "a slippery one." Elstad, 470 U. S., at 309; see, e. g., n. 1, supra (custody cases). And the supposedly "bright" lines that separate interrogation from spontaneous declaration, the exercise of a right from waiver, and the adequate warning from the inadequate, likewise have turned out to be rather dim and ill defined. See Rhode Island v. Innis, 446 U. S. 291 (1980) (interrogation); n. 2, supra (interrogation); nn. 4 and 5, supra (waiver and invocation); n. 3, supra (adequacy of warnings). Yet Miranda requires those lines to be drawn with precision in each case.
The totality-of-the-circumstances approach, on the other hand, permits each fact to be taken into account without re-
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