People v. Garza

Court properly granted Defendant's motion to suppress evidence. Defendant was in custody and was asked 2 interrogatory questions without prior Miranda warnings. Officer had directed occupants of vehicle to exit the vehicle, asked them for ID, and subjected them to a thorough search; officer never told them they could or could not leave. Officer asked them who owned a backpack found in vehicle, and asked them about the white powdery substance found inside it. Officer's search resembled a search incident to arrest and carried strong implications of police custody. (HOLDRIDGE, concurring; SCHMIDT, concurring in part and dissenting in part.)