Roadside questioning and custody
468 U.S. 420 (1984)
NationwideU.S. Supreme Court
Quick Rule
Ordinary roadside questioning during a traffic stop generally is not Miranda custody. Custody can arise when the restraint becomes comparable to formal arrest.
Field Reminder
Reassess custody as the encounter changes. Give warnings before custodial interrogation.
Important Limits
Being temporarily not free to leave does not alone establish Miranda custody. Once custodial interrogation occurs, Miranda applies even to misdemeanor offenses.
Sources
Opinion sources reviewed October 4, 2026. Editorial summaries; not a comprehensive review of later decisions or Florida-specific requirements. Follow agency policy, certified training, and State Attorney guidance.