Miranda warnings are required prior to questioning an individual in custody or otherwise deprived of his freedom in any significant way. (People v. Mayfield (1997) 14 Cal.4th 688; see also New York v. Quarles (1984) 467 U.S. 649 (holding a person in custody when under arrest or if his freedom of movement is retrained to a degree associated with a formal arrest).) As such, an individual is in custody where police action is the functional equivalent of a formal arrest. (People v. Powell (1967) 67 Cal.2d 32 (absent a formal arrest, handcuffing deprives a suspect of their freedom of movement, rendering them in custody).)
In determining whether a suspect was in custody, courts must examine the totality of the circumstances surrounding the interrogation