(1983)). 17 . Id. at 256 (quoting Berkemer v. McCarty, 468 U.S. 420, 442, 104 S.Ct. 3138, 82 L.Ed.2d 317 (1984)). 18 . See id. at 256 (“If a reasonable person would have thought he was free to leave, the Miranda inquiry is at an end. But if a reasonable person would not have thought himself free to leave, additional analysis is required because ... not every seizure constitutes cus tody for purposes of Miranda. The ultimate inquiiy is[,] was there a formal arrest or restraint on freedom of movement of the degree associated with a formal arrest.”) (internal punctuation and citations omitted). 19 . Even when the officers told appellant she had committed a crime by destroying Mr. Ward's property, they made it plain that she was not under arrest. 20 . See, e.g. Hughes, 640 F.3d at 435-37 (<HOLDING>); United States v. Titemore, 437 F.3d 251, 260
holding miranda inapplicable because defendant not in custody holding that a defendant who was told several times he was not under arrest and who never asked to leave during an interview with investigators was not in custody holding that defendant was not in miranda custody during knock and talk interview at his residence holding that defendant was not in custody during search of his residence holding testimony that defendant had no response to question during police interview was not impermissible comment on his constitutional right to remain silent where defendant had voluntarily waived his miranda rights