Whether reasonable jurists could debate the issue of custody for Miranda purposes

QUESTIONS PRESENTED i Whether reasonable jurists could debate the issue of custody for Miranda purposes, as ' various state and federal courts have, when an individual has béen detained, held d incommunicado in a police dominated atmosphere, and interrogated without receiving Miranda fa warnings? { Whether under the totality of circumstances approach, all relevant circumstances should { be considered in the custody analysis, including specific statements from interrogators that a ! defendant is not allowed to call anybody for help? . | ) Whether a state habeas petitioner may satisfy his burden under 28 U.S.C. 2253(c)(2) of i making a substantial showing of a constitutional right for the issuance of a certificate of | appealability by pointing to multiple rulings from other federal courts that have resolved the i : same claim “in a different manner” than the district court did in his case upon similar facts? ‘ | iF . : : . | : : ; . j oe jt it &