State of Utah, Plaintiff and Respondent v. Ralph Levin, Defendant and Petitioner

Summary

The Utah Supreme Court held that appellate review of a trial court’s custodial-interrogation determination under the Fifth Amendment is for correctness rather than abuse of discretion. It revised the framework for selecting standards of review for mixed questions of fact and law by adopting a three-factor, policy-based balancing test and concluded that the need for uniform Miranda rules requires nondeferential review. The court remanded for the court of appeals to apply the correctness standard; it did not decide whether Levin was actually in custody.