Dyer v. Hornbeck

The Court affirmed the "district court’s denial of a 28 U.S.C. § 2254 habeas corpus petition challenging the admission of statements Dyer made to police" and "concluded that fairminded jurists could disagree as to whether Dyer was “in custody” when she made certain disputed statements," therefore the "state court’s decision . . . was not an unreasonable application of the Supreme Court’s decision in Miranda v. Arizona, 384 U.S. 436 (1966), and its progeny."

Stacy Dyer, convicted of first degree felony murder, second degree robbery, and kidnapping, appealed from the Eastern District of California US District Court’s denial of “her 28 U.S.C. §2254 petition for a writ of habeas corpus.” Some information used at earlier trial was from an interview at a police station, to which Dyer had agreed to travel with the detectives in a police car from her home, during which Dyer had been allowed “unaccompanied breaks to the restroom,” and prior to starting, an officer told Dyer that she was not under arrest or in trouble and could leave at any time. “The Court of Appeal affirmed the trial court’s finding that Dyer was not “in custody” at the time she made the relevant statements, and that Miranda therefore did not apply.” The Court reviewed the district court’s decision de novo and considered “whether a “reasonable innocent person in such circumstances” would understand that she could refuse to answer officers’ questions and leave,” by examining the circumstances surrounding the interrogation and by determining whether there was a “formal arrest or restraint on freedom of movement.” The Court determined that the appellate court’s findings that “a reasonable innocent person in Dyer’s position would have understood herself to be free to ignore the detectives’ inquiries and leave” were objectively reasonable. Although the Court was troubled by the decisions by the courts below, it was bound by the Antiterrorism and Effective Death Penalty Act which provides that “habeas relief is appropriate only to remedy a state court’s “unreasonable application of” clearly established Supreme Court precedent.” The Court held “that [because] fairminded jurists could disagree as to whether Dyer was “in custody” when she made the statements in dispute, we affirm the district court’s denial of Dyer’s application for habeas relief.” AFFIRMED.