People v. Centano, 76 N.Y.2d 837 (1990)
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Whether a suspect is in custody for Miranda purposes is a factual determination based on whether a reasonable person, innocent of any crime, would have believed they were in custody under the circumstances.
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Summary
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Centano voluntarily went to the police station to assist in a homicide investigation. Over 28 hours, he failed two polygraph tests and provided false information. Despite being allowed to relax, eat, and sleep in an unlocked room, the Court of Appeals determined the interrogation remained noncustodial. The court emphasized Centano’s voluntary appearance, the non-coercive atmosphere, and the police’s statements that he wasn’t a suspect. The dissent argued that after 28 hours of questioning and failed polygraphs, a reasonable person wouldn’t feel free to leave, thus Miranda warnings were required. Ultimately, the majority upheld the lower court’s finding that the interrogation was noncustodial because reasonable minds could differ on the inferences drawn from the facts.
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Facts
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Defendant Centano voluntarily went to the police precinct to offer assistance in the investigation of Ivory’s death, presenting himself as a friend. During the following 28 hours: (1) He failed two polygraph tests concerning the homicide. (2) Two stories he told police about possible perpetrators were exposed as lies. (3) He was constantly in the presence of the police, even escorted to the bathroom. (4) When he stated he no longer wished to cooperate, he was asked to take a second polygraph and stay overnight. (5) He slept on a bench in an unlocked room. (6) He was allowed to go into a store unescorted, though police waited outside.
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Procedural History
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The Supreme Court determined there was no custodial interrogation. The Appellate Division affirmed. The New York Court of Appeals reviewed the Appellate Division’s order, considering whether the undisturbed findings of the lower courts were based on the correct legal standard and supported by the record.
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Issue(s)
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Whether, as a matter of law, the proof was insufficient to establish that Centano’s interrogation was noncustodial, considering the length of the interrogation, the polygraph results, and other circumstances.
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Holding
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No, because the totality of the circumstances, including Centano’s voluntary appearance, the non-coercive atmosphere, the investigative (not accusatory) questioning, and the express statement that he was not a suspect, provide sufficient evidence to establish that the interrogation was noncustodial. At a minimum, reasonable minds may differ as to the inferences to be drawn.
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Court’s Reasoning
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The Court of Appeals applied the standard from People v. Yukl, which states that custody is determined from the viewpoint of a reasonable person in the defendant’s position. The Court listed twelve factors supporting the conclusion that a reasonable person would not have believed he was in custody. These included his voluntary appearance, the non-coercive atmosphere, that he was expressly told he wasn’t a suspect, that he was never handcuffed or physically restrained, that the questioning was interrupted frequently, that he never protested the questioning, that he was fed and allowed to relax, that he was allowed to sleep alone in an unlocked room, and that he was permitted to go unescorted into a store. The court stated that its review power is limited when reasonable minds may differ as to the inferences to be drawn from the facts. Judge Titone’s dissent argued that after failing two lie detector tests and being questioned for 28 hours, no sensible person would believe they were free to leave, and therefore Miranda warnings were required. The dissent also expressed concern that the