IN MIRANDA V. ARIZONA, THE SUPREME COURT HELD THAT THE DEFENDANT MUST BE PROTECTED AGAINST SELF-INCRIMINATIONS: HE MUST BE ADVISED THAT HE HAS A RIGHT TO REMAIN SILENT; THAT ANYTHING HE SAYS MAY BE USED AGAINST HIM; THAT HE HAS A RIGHT TO HAVE AN ATTORNEY PRESENT DURING QUESTIONING; AND THAT IF HE CANNOT AFFORD AN ATTORNEY, ONE WILL BE APPOINTED FOR HIM. TWO MAJOR ISSUES INVOLVED IN THE MIRANDA DECISION CONCERN THE DEFINITION OF CUSTODY AND WHAT CONSTITUTES A WAIVER OF THE RIGHT TO COUNSEL. THE MIRANDA SAFEGUARDS ARE LIMITED TO CUSTODIAL INTERROGATION; IN A NONCUSTODIAL SITUATION THE WARNING ARE NOT REQUIRED TO BE GIVEN. IF A SUSPECT IS ACTUALLY IN CUSTODY AND MAKES A STATEMENT WHICH IS TO BE USED AGAINST HIM, THE COURT MUST FIND THAT THE SUSPECT KNOWINGLY AND VOLUNTARILY WAIVED HIS RIGHTS TO SILENCE AND TO AN ATTORNEY BEFORE ADMITTING THE STATEMENT AS EVIDENCE. TWO TESTS WHICH HAVE BEEN USED ARE THOSE OF 'FOCUS' AND 'OBJECTIVITY.' THE SUSPECT HAS A RIGHT TO CONSEL WHEN THE FOCUS OF QUESTIONING SHIFTS FROM INVESTIGATORY TO ACCUSATORY, AND A SUSPECT IS IN CUSTODY WHEN UNDER THE PARTICULAR CIRCUMSTANCES A REASONABLE MAN WOULD OBJECTIVELY BELIEVE HIMSELF TO BE IN CUSTODY. HOWEVER THE TREND OF THE BURGER COURT HAS BEEN TO NARROW THE DEFINITION OF CUSTODIAL INTERROGATION, THUS NARROWING THE CIRCUMSTANCES IN WHICH THE MIRANDA GUIDELINES ARE IN EFFECT. DECISIONS IN SEVERAL SPECIFIC CASES WHICH ILLUSTRATE THIS TREND ARE ANALYZED. (VDA)