In the case of David Bobby, Warden v. Archie Dixon in 2011, the U.S. Supreme Court ruled that a suspect's Miranda rights were not violated when police questioned him without reading his rights because he was not officially in custody at the time. The case involved Archie Dixon who had been convicted for murder and theft after confessing to killing a man and stealing his car during an informal conversation with detectives while he was free to leave at any point. He appealed on grounds that his confession should have been suppressed as evidence since he wasn't read his Miranda warnings prior to questioning by law enforcement officers. However, the court held that since Dixon was not under arrest or restrained from leaving during questioning, it did not constitute custodial interrogation which would require Miranda warnings be given.

In the dissenting opinion for David Bobby, Warden v. Archie Dixon, Justice Sotomayor argued that the majority's decision to deny habeas relief was based on an overly narrow interpretation of clearly established Federal law. She contended that the Ohio Supreme Court had unreasonably applied federal law by failing to consider whether Dixon’s confession was voluntary in light of all circumstances surrounding it and not just his Miranda waiver. The justice believed this approach contradicted previous rulings which stated a court must assess 'the totality of all the surrounding circumstances' when determining if a confession is truly voluntary or coerced. Furthermore, she criticized their failure to address how police deception affected Dixon's ability to make an informed choice about waiving his rights before confessing.