During the course of a traffic stop, the appellee made incriminating statements. The trial court suppressed the statements. In evaluating whether a reasonable person would believe his freedom has been restrained to the degree of formal arrest, the court looks only to the objective factors surrounding the detention. The subjective beliefs of the detaining officer are not included in the calculation of whether a suspect is in custody. The court of appeals' judgment is affirmed. Court of Criminal Appeals, No. PD-1181-11, 10-31-2012.
State v. Ortiz
Tex. Crim. App.
November 5, 2012
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