In the case of Robert Edward Stansbury v. California, 1993, the U.S Supreme Court ruled that an individual's perception of their freedom to leave during police questioning is not solely determined by whether a law enforcement officer has declared them a suspect. The court held that this determination should be based on how reasonable people in similar circumstances would perceive their situation. This decision was made after Robert Edward Stansbury appealed his murder conviction arguing that he had been subjected to custodial interrogation without being read his Miranda rights because he was considered a prime suspect at the time of questioning. However, the Supreme Court disagreed with him stating that even though officers may have suspicions about someone's involvement in a crime it does not automatically make them "in custody" for purposes of receiving Miranda warnings.

In the dissenting opinion of Stansbury v. California, it was argued that the majority's decision blurred the line between noncustodial and custodial interrogation, creating confusion for law enforcement officers. The dissent emphasized that a suspect should only be considered in custody when there is a formal arrest or restraint on freedom of movement to an extent associated with formal arrest. They disagreed with the majority’s view that subjective intentions of police officers can determine whether someone is 'in custody' for Miranda purposes if those intentions are communicated to the individual being questioned. This perspective could potentially lead every traffic stop or street encounter into a custodial situation requiring Miranda warnings, which would complicate routine investigations and undermine effective law enforcement.