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Arizona Supreme Court: Curbside Questioning Does Not Require Miranda Warning

The Arizona Supreme Court has ruled that police conducting on the scene questioning are not required to issue a Miranda warning.

The issue in the Arizona v. Carlos Andres Maciel case centers on whether Maciel, who was convicted of burglary, was technically in police custody when he made incriminating statements.

Maciel was found near the scene of a burglary in 2013. Officers responding had the man sit in a police car and then on a curb when they asked him what he knew about the removal of a wooden window covering.

In trial court, Maciel’s attorneys argued his confession should be suppressed because he had not been read his Miranda rights. The justice upheld the decision to deny this motion because the curbside questioning did not present “inherently coercive pressures” like a station interrogation.

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Carrie Jung was a senior field correspondent from 2014 to 2018.