OCTOBER TERM, 1995
Syllabus
certiorari to the united states court of appeals for the ninth circuit
No. 94-6615. Argued October 11, 1995—Decided November 29, 1995
During a two-hour, tape-recorded session at Alaska state trooper headquarters, petitioner Thompson confessed he had killed his former wife. Thompson maintained that the troopers gained his confession without according him the warnings required by Miranda v. Arizona, 384 U. S. 436. The Alaska trial court denied his motion to suppress the confession, however, ruling that he was not "in custody" for Miranda purposes, therefore the troopers were not required to inform him of his Miranda rights. After a trial at which the prosecution played the tape-recorded confession, the jury found Thompson guilty of first-degree murder, and the Court of Appeals of Alaska affirmed his conviction. The Federal District Court denied Thompson's petition for a writ of habeas corpus, and the Ninth Circuit affirmed. Both courts held that a state court's ruling that a defendant was not "in custody" for Miranda purposes qualifies as a "fact" determination entitled to a presumption of correctness under 28 U. S. C. § 2254(d).
Held: State-court "in custody" rulings, made to determine whether Miranda warnings are due, do not qualify for a presumption of correctness under § 2254(d). Such rulings do not resolve "a factual issue." Instead, they resolve mixed questions of law and fact and therefore warrant independent review by the federal habeas court. Pp. 107-116. (a) Section 2254(d) declares that, in a federal habeas proceeding instituted by a person in custody pursuant to a state-court judgment, the state court's determination of "a factual issue" ordinarily "shall be presumed to be correct." This Court has held that "basic, primary, or historical facts" are the "factual issue[s]" to which the statutory presumption of correctness dominantly relates. See, e. g., Miller v. Fenton, 474 U. S. 104, 112. Nonetheless, the proper characterization of a question as one of fact or law is sometimes slippery. Two lines of decisions compose the Court's § 2254(d) law/fact jurisprudence. In several cases, the Court has classified as "factual issues" within § 2254(d)'s compass questions extending beyond the determination of "what happened." The resolution of the issues involved in these cases, notably competency to stand trial and juror impartiality, depends heavily on the trial court's superior ability to appraise witness credibility and demeanor. On the
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