United States v. Erving L. (A Juvenile)

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that an adolescent suspect interviewed by plainclothes officers in his living room with his parents present was not in custody
• holding that two officers in a common area of the defendant’s home did not create a police-dominated atmosphere
• noting that courteous and nonthreatening nature of police actions weighed against a conclusion the defendant was in custody
• noting that suspects are less likely to be found to have been in custody for Miranda purposes if they were interviewed in their own homes
• noting that the overall custody analysis is a mixed question of fact and law reviewed de novo, “with proper deference to the district court’s findings of historical fact”
• “Given these facts, a reasonable juvenile in E.L.’s position would not have believed that the officers had curtailed his freedom of movement to a degree associated with formal arrest.”

Source: CourtListener parenthetical corpus (CC0).