Deft's unmirandized statements were made in an apparent situation that, if taken as true, would have been considered sufficiently custodial. Absent any evidence in the record of counsel's strategic considerations in not attempting to suppress the confession, an evidentiary hearing is warranted for the collateral challenge, especially since the deft was, as a matter of law, prejudiced by the admission.
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.