How have the courts interpreted the term "interrogation" under the Miranda Act?

"[T]he term 'interrogation' under Miranda refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect." (Rhode Island v. Innis (1980) 446 U.S. 291, 301.) Defendant argues that the removal of the chain implicitly accused him of a crime, and therefore it was reasonably likely to provoke an incriminating response. We think this proves too much. Under this reasoning, any number of the incidents of arrest would be deemed to be interrogation e.g., handcuffing a suspect, patting a suspect down, or placing a suspect in a patrol car. So would appropriate investigative steps, such as

Page 11