429 U.S. 492 (1977) (per curiam)
Oregon v. Mathiason is a cornerstone Miranda custody case that delineates when police questioning triggers the requirement to administer Miranda warnings.
Does a voluntary, stationhouse interview—where the suspect is told he is not under arrest and is free to leave—constitute "custody" requiring Miranda warnings, even if the interview occurs in a closed office and includes police deception?
Miranda warnings are required only for custodial interrogation. A person is in custody for Miranda purposes if there is a formal arrest or a restraint on freedom of movement of the degree associated with a formal arrest—i.e., if the suspect is deprived of freedom of action in any significant way. The mere fact that an interrogation occurs at a police station or that it has inherently coercive aspects does not, without more, establish custody.
No. Mathiason was not in custody during the initial interview; therefore, Miranda warnings were not required before his initial admission. The confession was admissible.
Mathiason is a foundational Miranda-custody case establishing that the touchstone is custody—not the setting's coerciveness. It teaches that voluntariness in appearing for questioning, an express statement that the person is not under arrest, the ability to leave after questioning, and the absence of physical restraint strongly weigh against a custody finding. The case is frequently paired with California v. Beheler to underscore that stationhouse interviews can be noncustodial. For students, Mathiason clarifies how to separate the Miranda custody inquiry from voluntariness and from Fourth Amendment seizure concepts, and it provides a practical checklist of facts to analyze in suppression problems.