21 N.Y.2d 1 (1967)

The requirement to administer Miranda warnings arises when an individual is subjected to custodial interrogation, defined as questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.

Summary

This case addresses the scope of *Miranda v. Arizona* regarding when police are required to administer warnings to a suspect who is not formally under arrest. Rodney P., a 16-year-old, was questioned by a detective at his home about a stolen car and admitted his involvement. He was not given *Miranda* warnings at any point. The Court of Appeals of New York held that the oral admissions were admissible because Rodney was not in custody or otherwise deprived of his freedom in a significant way during the questioning at his home. The court emphasized the need to examine the circumstances and atmosphere of the interrogation to determine if a reasonable person would believe their freedom was restrained.

Facts

Daniel W. was arrested for stealing a car and identified Rodney P. as his accomplice.
Detectives went to Rodney’s home, where one detective questioned him outside his house.
Rodney admitted to taking the car with Daniel.
This questioning lasted about three to four minutes.
Rodney was then taken inside, and his father was contacted via phone regarding the arrest.
At police headquarters, Rodney signed a written statement summarizing the conversation.
Rodney was never advised of his *Miranda* rights.

Procedural History

Rodney was charged with grand larceny and approved for youthful offender treatment.
A motion to suppress the oral admissions and written statement was filed.
The court suppressed the written statement due to the lack of *Miranda* warnings but refused to suppress the oral admissions.
The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

Issue(s)

Whether the oral admissions made by Rodney P. to the police officer at his home were unconstitutionally obtained and should have been suppressed because he was not given *Miranda* warnings before being questioned.

Holding

No, because Rodney P. was not in custody or otherwise deprived of his freedom of action in any significant way when he was questioned at his home; therefore, *Miranda* warnings were not required.

Court’s Reasoning

The Court of Appeals focused on whether Rodney was subjected to