Whether an interrogation in a secured facility between a probationer and armed law enforcement is custodial for Miranda purposes

QUESTIONS PRESENTED A state probation officer, acting at the request of police detectives, directed the petitioner to sit with them for an interrogation at the probation office following a regularly scheduled check-in. The probation office was a locked and secured environment, where freedom of movement was restricted and staff escorts were required. The interrogation took place in a probation supervisor’s office where the petitioner had never been before, on a different floor than his probation officer’s. The petitioner was not provided a Miranda advisement during this interrogation. The interrogation yielded information which ultimately contributed to the petitioner’s conviction for the homicide in question. The trial court denied a motion to suppress statements made during that interrogation, and a divided state supreme court affirmed. In J.D.B. v. North Carolina, 564 U.S. 261 (2011), this Court held that the distinct coercive pressures faced by children as a class required courts to undertake a more searching analysis of whether a juvenile suspect would have felt that he or she was not free to terminate police questioning and leave. The questions presented are: (1) Whether an interrogation in a secured facility between a probationer who is present on the orders of his probation officer, and armed law enforcement, is custodial for purposes of Miranda v. Arizona. (2) Whether, in accordance with J.D.B. v. North Carolina, the coercive pressures unique to probationers and parolees as a class must be given additional weight by courts when determining custodial status for Miranda purposes.