The following excerpt is from Cervantes v. Walker, 589 F.2d 424 (9th Cir. 1978):
In contrast to custodial interrogation, on-the-scene questioning does not require Miranda warnings. Id. at 477-78, 86 S.Ct. 1602. Such questioning enables an officer "to determine whether a crime has been committed or is in progress." Lowe v. United States, 407 F.2d 1391, 1393-94 (9th Cir. 1969).
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