People v. Coleman

Initial determination of custody depends on objective circumstances of interrogation, not on subjective views harbored by officers or by person being questioned. A failure to admonish a defendant pursuant to Miranda warnings cannot be excused based on mere fact that Defendant incorrectly believed he was not in custody for Miranda purposes. Defendant was handcuffed and questioned about any independent crime, which objectively would have led a reasonable person to believe he was not free to leave or terminate encounter. Under totality of circumstances, defendant was entitled to be given Miranda warnings before being questioned because he was in custody for Miranda purposes.(HARRIS, concurring; STEIGMANN, dissenting.)