1312, 1317, 1318 (10th Cir.1994). Owens was initially present at the Eidsons’ farm to check on Kim Eidson after her altercation with another woman. When Owens was told by other deputies that the Eidsons’ son had turned them in for growing marijuana, Owens relayed that (mistaken) fact to Kim, who then confessed. She was not in custody at that point. See United States v. Bennett, 329 F.3d 769, 774 (10th Cir.2003) (noting that a suspect is not in custody until her “freedom of action is curtailed to a degree associated with formal arrest”) (quotation omitted). Even if Kim’s contact with the deputies ripened into custody during the search, nothing indicates that Owens interrogated her after the search began. See Rhode Island v. Innis, 446 U.S. 291, 301, 100 S.Ct. 1682, 64 L.Ed.2d 297 (1980) (<HOLDING>) (footnote omitted). The same is true for Keith
holding that fifth amendment protection against selfincrimination requires police to notify suspect of right to counsel and to cut off interrogation once suspect invokes the right absent counsel further interrogation may not occur unless suspect initiates subsequent conversation if police initiate subsequent interrogation there can be no valid waiver of counsel even though police advise suspect of his or her constitutional rights and suspect acquiesces in the interrogation recognizing routine booking question exception observing that the underlying rationale for the exception is that routine booking questions do not constitute interrogation because they do not normally elicit incriminating responses and holding that where questions regarding normally routine biographical information are designed to elicit incriminating information the questioning constitutes interrogation subject to the strictures of miranda   citations omitted holding that defendants inculpatory statements were not the product of interrogation where a detective could not have known his words would elicit an incriminating response holding that there was no interrogation where the police asked only routine booking questions that did not relate even tangentially to criminal activity moreover there is no evidence that the defendant was particularly susceptible to these questions or that police somehow used the questions to elicit an incriminating response from the defendant holding that an interrogation occurs when there is express questioning or any words or actions on the part of the police other than those normally attendant to arrest and custody that the police should know are reasonably likely to elicit an incriminating response from the suspect