How have the courts dealt with a motion to suppress evidence of a videotaped interview with the police?

At trial, defendant moved to suppress evidence of his videotaped interview with the police on the ground that he was unlawfully seized under the Fourth Amendment when taken to the detective bureau and subjected to custodial interrogation without being given Miranda warnings (Miranda v. Arizona (1966) 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 ). The trial court denied the motion. It found that because defendant was not in custody, Miranda warnings were not required. Consequently, the prosecution played for the jury the videotape of defendant's interview during its case-in-chief. On appeal, defendant contends that the trial court erred in denying his suppression motion. We find no error. We conclude that defendant was not seized when taken to the detective bureau and not in custody when questioned by the detectives.

[347 P.3d 964]