Defendant was a passenger in a car stopped for a traffic violation. The driver consented to a search of the car, which authorizes the police to detain everyone in the car while the consent search is completed. During the search, the officer found marijuana on the passenger side floorboard, and he told defendant and the driver that they both would be arrested if they did not own up to who owned the drugs. Defendant admitted they were his. When the driver of a car lawfully stopped for a traffic violation consents to a search of the car, the traffic stop becomes a consensual encounter. However, the officer is allowed to detain all occupants of the car until he completes the search.
Held: Defendant was in custody for Miranda purposes, and the court errs in denying his motion to suppress.