According to the Supreme Court in Miranda, custody exists only when a person has been taken into custody and formally arrested.

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In Miranda v. Arizona, the Supreme Court defined custody as a situation where a person's freedom of action is curtailed to a degree associated with formal arrest, not solely based on formal arrest status. This includes situations where a reasonable person would not feel free to leave, even if they haven't been formally arrested.

According to the Supreme Court in Miranda, Custody Exists Only