King v. Bureau of Indian Affairs

How later courts describe this case

• holding that statements made by a victim to-police officers after she was shot were admissible under the “excited utterance” exception as they described the circumstances surrounding the shooting and immediately followed the shooting
• holding that a human-made tributary fell under the Act
• noting that "the rule of Miranda applies only where a defendant is subjected to custodial interrogation," and that, "similarly, N.C.G.S. § 7A-595(d) [now N.C.G.S. § 7B-2101(a)] pertains only to statements obtained from a juvenile defendant as the result of custodial interrogation"
• upholding conclusion that defendant was not in custody where he was told several times that he was not under arrest and was free to leave, and defendant signed a statement including a clause to that effect
• statute "pertains only to statements obtained from a juvenile defendant as the result of custodial interrogation"
• to detain a person is to “arrest, ... to delay, to hinder, to hold, or keep in custody”
• "[The North Carolina Supreme Court] has consistently held that the rule of Miranda applies only where a defendant is subjected to custodial interrogation."