114
Opinion of the Court
See Berkemer v. McCarty, 468 U. S. 420, 442 (1984) (court must assess "how a reasonable man in the suspect's position would have understood his situation"); cf. Miller, 474 U. S., at 116-117 ("[A]ssessments of credibility and demeanor are not crucial to the proper resolution of the ultimate issue of 'voluntariness.' ").
Unlike the voir dire of a juror, Patton, 467 U. S., at 1038, or the determination of a defendant's competency, Maggio, 462 U. S., at 117, which "take[s] place in open court on a full record," Miller, 474 U. S., at 117, the trial court does not have a first-person vantage on whether a defendant was "in custody" for Miranda purposes. See 474 U. S., at 117 (police interrogations yielding confessions ordinarily occur, not in court, but in an "inherently more coercive environment"). Furthermore, in fathoming the state of mind of a potential juror or a defendant in order to answer the questions, "Is she free of bias?," "Is he competent to stand trial?," the trial court makes an individual-specific decision, one unlikely to have precedential value.14 In contrast, "in custody" determinations do guide future decisions.15 We thus conclude
of police presence, is not coerced); Berkemer v. McCarty, 468 U. S. 420, 436-439 (1984) (nature of suspected offense is irrelevant to duty to administer Miranda warnings); Oregon v. Mathiason, 429 U. S. 492, 495-496 (1977) (per curiam) (fact that interrogation occurs at police station does not, in itself, require Miranda warnings).
14 In other contexts, we have similarly concluded that the likely absence of precedential value cuts against requiring plenary appellate review of a district court's determination. For example, in Cooter & Gell v. Hart-marx Corp., a decision confirming that the abuse-of-discretion standard applies to appellate review of sanctions under Federal Rule of Civil Procedure 11, we observed that plenary review would likely " 'fail to produce the normal law-clarifying benefits that come from an appellate decision on a question of law . . . .' " 496 U. S., at 404 (quoting Pierce v. Underwood, 487 U. S. 552, 561 (1988)).
15 See, e. g., Stansbury v. California, 511 U. S. 318, 322-324 (1994) (per curiam) (review of precedent demonstrated a "well settled" principle: officer's undisclosed, subjective belief that person questioned is a suspect is irrelevant to objective "in custody" determination); Pennsylvania
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