Indiana v. Ernesto Ruiz

In the decision below the Indiana Supreme Court held that statements Ernesto Ruiz made during a station-house interview were inadmissible under Miranda v. Arizona, 384 U.S. 436, 444 (1966), because the interview constituted a “custodial interrogation.” To support this conclusion—which the Court reached even though Ruiz freely drove himself to and from the station and was told he could leave at any time—the Court gave substantial weight to the station’s ordinary security features and layout, namely a “circuitous path” to the interview room and a door that, while locked for entrance, was (unbeknownst to Ruiz) unlocked for exit. Pet. App. 8. In weighing such ordinary features as it did, the Indiana Supreme Court both contradicted holdings of the Seventh Circuit and deepened a preexisting split among the lower courts. The question presented is: When analyzing whether a station-house interview is a custodial interrogation under Miranda, do the ordinary security features and layout of a police station weigh in favor of a determination that the interview was “custodial”?