State v. Spencer , 319 Ark. 454, 457, 892 S.W.2d 484, 485 (1995) (citing Miranda v. Arizona , 384 U.S. 436, 444, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1965) ). A person is “in custody” for purposes of Miranda warnings when he or she is “deprived of his freedom by formal arrest or restraint on freedom of movement of the degree associated with a formal arrest.” Hall v. State , 361 Ark. 379, 389, 206 S.W.3d 830, 837 (2005) (citing Wofford v. State , 330 Ark. 8, 28, 952 S.W.2d 646, 656 (1997) ). The Miranda safeguards become applicable as soon as a suspect's freedom of action is curtailed to a degree associated with formal arrest.

Miranda warnings are required only in the context of a custodial interrogation. Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005); Wofford v. State, 330 Ark. 8, 952 S.W.2d 646 (1997). A person is in custody for purposes of the Miranda warnings when he or she is “deprived of his freedom by formal arrest or restraint on freedom of movement of the degree associated with a formal arrest.”

The State contends that Flanagan was not in custody when she made the statements on June 12; therefore, the Miranda warnings were not necessary. In Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005), we stated: This court has held that the safeguards prescribed by Miranda become applicable as soon as a suspect's freedom of action is curtailed to a degree associated with formal arrest.

This court has repeatedly held that motions for a directed verdict are treated as challenges to the sufficiency of the evidence. Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005); Martin v. State, 354 Ark. 289, 119 S.W.3d 504 (2003); Sublett v. State, 337 Ark. 374, 989 S.W.2d 910 (1999). The test for determining the sufficiency of the evidence is whether substantial evidence, direct or circumstantial, supports the verdict.

Miranda warnings are required only in a custodial-interrogation situation. Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005). A person is "in custody" for purposes of Miranda warnings when he or she is "deprived of his freedom by formal arrest or restraint on freedom of movement of the degree associated with a formal arrest." Id. at 389, 206 S.W.3d at 837.

Miller also testified that he told Tennant and Self that if no one "owned this stuff," he would arrest them all. In Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005), the supreme court noted that "the term 'interrogation' under Miranda refers not only to express questioning, but also to 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." Hall, 361 Ark. at 389, 206 S.W.3d at 836 (quoting State v. Pittman, 360 Ark. 273, 200 S.W.3d 893 (2005), and Rhode Island v. Innis, 446 U.S. 291 (1980)).

Miranda warnings, therefore, are necessary at the time of a custodial interrogation. Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005). In the absence of such warnings, “the [State] may not use statements, whether exculpatory or inculpatory, stemming from the custodial interrogation....” Rhode Island v. Innis, 446 U.S. 291, 297, 100 S.Ct. 1682, 64 L.Ed.2d 297 (1980) ; see also Shelton v. State, 287 Ark. 322, 699 S.W.2d 728 (1985) (holding that, once in custody, no interrogation is allowed absent the Miranda warnings and a knowing, voluntary waiver).

Miller also testified that he told Tennant and Self that if no one “owned this stuff,” he would arrest them all. In Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005), the supreme court noted that “the term ‘interrogation’ under Miranda refers not only to express questioning, but also to 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.” Hall, 361 Ark. at 389, 206 S.W.3d at 836 (quoting State v. Pittman, 360 Ark. 273, 200 S.W.3d 893 (2005), and Rhode Island v. Innis, 446 U.S. 291, 100 S.Ct. 1682, 64 L.Ed.2d 297 (1980) ).

In the felony-murder case of State v. Shepherd, 902 S.W.2d 895, 901 (Tenn.1995), this Court established that “[t]he corpus delicti in a homicide case.... consists of two (2) elements: (1) the death of a human being and (2) criminal agency in producing that death.” See also Hall v. State, 361 Ark. 379, 206 S.W.3d 830, 835 (2005) (“[S]o long as the corpus delicti of the homicide (i.e., death caused by a criminal agency) is established by independent evidence, the predicate felony may be shown by confession alone.”); Ashby v. State, 124 Tenn. 684, 698–99, 139 S.W. 872, 875 (1911) (“[T]he corpus delicti ... in homicide cases [is] the death of a human being, and criminal agency in producing that death.”). The Court of Criminal Appeals has applied this rule in other Tennessee felony murder cases.

Evidence demonstrating the connection of the accused with the crime is simply not an element of the corpus delicti. Hall v. State, 361 Ark. 379, 206 S.W.3d 830 (2005) (citing Hart v. State, 301 Ark. 200, 783 S.W.2d 40 (1990)). Here, the State presented evidence that Ritchey died at the hands of another; that Telford's home was burglarized; and that Telford's guns were removed from his home.