Justice Ginsburg
delivered the opinion of the Court.
During a two-hour, tape-recorded session at Alaska state trooper headquarters, petitioner Carl Thompson confessed that he killed his former wife. Thompson’s confession was placed in evidence at the ensuing Alaska state-court trial, [102]*102and he was convicted of first-degree murder. Challenging his conviction in a federal habeas corpus proceeding, Thompson maintained that the Alaska troopers gained his confession without according him the warnings Miranda v. Arizona, 384 U. S. 436 (1966), requires: that he could remain silent; that anything he said could be used against him in court; and that he was entitled to an attorney, either retained or appointed.
Miranda warnings are due only when a suspect interrogated by the police is “in custody.” The state trial and appellate courts determined that Thompson was not “in custody” when he confessed. The statute governing federal habeas corpus proceedings, 28 U. S. C. § 2254, directs that, ordinarily, state-court fact findings “shall be presumed to be correct.” § 2254(d). The question before this Court is whether the state-court determination that Thompson was not “in custody” when he confessed is a finding of fact warranting a presumption of correctness, or a matter of law calling for independent review in federal court. We hold that the issue whether a suspect is “in custody,” and therefore entitled to Miranda warnings, presents a mixed question of law and fact qualifying for independent review.
I
On September 10, 1986, two moose hunters discovered the body of a dead woman floating in a gravel pit lake on the outskirts of Fairbanks, Alaska. The woman had been stabbed 29 times. Notified by the hunters, the Alaska state troopers issued a press release seeking assistance in identifying the body. Thompson called the troopers on September 11 to inform them that his former wife, Dixie Thompson, fit the description in the press release and that she had been missing for about a month. Through a dental examination, the troopers conclusively established that the corpse was Dixie Thompson. On September 15, a trooper called [103]*103Thompson and asked him to come to headquarters, purportedly to identify personal items the troopers thought belonged to Dixie Thompson. It is now undisputed, however, that the trooper’s primary reason for contacting Thompson was to question him about the murder.
Thompson drove to the troopers’ headquarters in his pickup truck and, upon arriving, immediately identified the items as Dixie’s. He remained at headquarters, however, for two more hours while two unarmed troopers continuously questioned him in a small interview room and tape-recorded the exchange. The troopers did not inform Thompson of his Miranda rights. Although they constantly assured Thompson he was free to leave, they also told him repeatedly that they knew he had killed his former wife. Informing Thompson that execution of a search warrant was underway at his home, and that his truck was about to be searched pursuant to another warrant, the troopers asked questions that invited a confession. App. 43-79.1 Eventually, Thompson told the troopers he killed Dixie.
[104]*104As promised, the troopers permitted Thompson to leave, but impounded his truck. Left without transportation, Thompson accepted the troopers’ offer of a ride to his friend’s [105]*105house. Some two hours later, the troopers arrested Thompson and charged him with first-degree murder.
The Alaska trial court, without holding an evidentiary hearing, denied Thompson’s motion to suppress his September 15 statements. Tr. 118 (Dec. 12,1986); Tr. 142 (Mar. 18, 1987). Deciding the motion on the papers submitted, the trial court ruled that Thompson was not “in custody” for Miranda purposes, therefore the troopers had no obligation to inform him of his Miranda rights. App. 8-9.2 Applying an objective test to resolve the “in custody” question, the court asked whether “ ‘a reasonable person would feel he was not free to leave and break off police questioning.’” Id., at 7 (quoting Hunter v. State, 590 P. 2d 888, 895 (Alaska 1979)). These features, the court indicated, were key: Thompson arrived at the station in response to a trooper’s request; two unarmed troopers in plain clothes questioned him; Thompson was told he was free to go at any time; and he was not arrested at the conclusion of the interrogation. App. 7-8. Although the trial court held that, under the totality of the circumstances, a reasonable person would have felt free to leave, it also observed that the troopers’ subsequent actions — releasing and shortly thereafter arresting Thompson — rendered the question “very close.” Id., at 8-9.
After a trial, at which the prosecution played the tape-recorded confession, the jury found Thompson guilty of first-degree murder and tampering with evidence. The Court of Appeals of Alaska affirmed Thompson’s conviction, concluding, among other things, that the troopers had not placed Thompson “in custody,” and therefore had no obligation to give him Miranda warnings. Thompson v. State, [106]*106768 P. 2d 127,131 (Alaska App. 1989).3 The Alaska Supreme Court denied discretionary review. App. 24.
Thompson filed a petition for a writ of habeas corpus in the United States District Court for the District of Alaska. The District Court denied the writ, according a presumption of correctness under 28 U. S. C. § 2254(d) to the state court’s conclusion that, when Thompson confessed, he was not yet “in custody” for Miranda purposes. App. 37. The Court of Appeals for the Ninth Circuit affirmed without publishing an opinion. 34 F. 3d 1073 (1994). Based on Circuit precedent,4 the court held that “a state court’s determination that a defendant was not in custody for purposes of Miranda is a question of fact entitled to the presumption of correctness under 28 U. S. C. § 2254(d).” App. 41.
Federal Courts of Appeals disagree on the issue Thompson asks us to resolve: whether state-court “in custody” determinations are matters of fact entitled to a presumption of correctness under 28 U. S. C. § 2254(d), or mixed questions of law and fact warranting independent review by the federal habeas court. Compare Feltrop v. Delo, 46 F. 3d 766, 773 (CA8 1995) (applying presumption of correctness), with Jacobs v. Singletary, 952 F. 2d 1282, 1291 (CA11 1992) (conducting independent review). Because uniformity among federal courts is important on questions of this order, we granted certiorari to end the division of authority. 513 U. S. [107]*1071126 (1995). We now hold that the 28 U. S. C. § 2254
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Justice Ginsburg
delivered the opinion of the Court.
During a two-hour, tape-recorded session at Alaska state trooper headquarters, petitioner Carl Thompson confessed that he killed his former wife. Thompson’s confession was placed in evidence at the ensuing Alaska state-court trial, [102]*102and he was convicted of first-degree murder. Challenging his conviction in a federal habeas corpus proceeding, Thompson maintained that the Alaska troopers gained his confession without according him the warnings Miranda v. Arizona, 384 U. S. 436 (1966), requires: that he could remain silent; that anything he said could be used against him in court; and that he was entitled to an attorney, either retained or appointed.
Miranda warnings are due only when a suspect interrogated by the police is “in custody.” The state trial and appellate courts determined that Thompson was not “in custody” when he confessed. The statute governing federal habeas corpus proceedings, 28 U. S. C. § 2254, directs that, ordinarily, state-court fact findings “shall be presumed to be correct.” § 2254(d). The question before this Court is whether the state-court determination that Thompson was not “in custody” when he confessed is a finding of fact warranting a presumption of correctness, or a matter of law calling for independent review in federal court. We hold that the issue whether a suspect is “in custody,” and therefore entitled to Miranda warnings, presents a mixed question of law and fact qualifying for independent review.
I
On September 10, 1986, two moose hunters discovered the body of a dead woman floating in a gravel pit lake on the outskirts of Fairbanks, Alaska. The woman had been stabbed 29 times. Notified by the hunters, the Alaska state troopers issued a press release seeking assistance in identifying the body. Thompson called the troopers on September 11 to inform them that his former wife, Dixie Thompson, fit the description in the press release and that she had been missing for about a month. Through a dental examination, the troopers conclusively established that the corpse was Dixie Thompson. On September 15, a trooper called [103]*103Thompson and asked him to come to headquarters, purportedly to identify personal items the troopers thought belonged to Dixie Thompson. It is now undisputed, however, that the trooper’s primary reason for contacting Thompson was to question him about the murder.
Thompson drove to the troopers’ headquarters in his pickup truck and, upon arriving, immediately identified the items as Dixie’s. He remained at headquarters, however, for two more hours while two unarmed troopers continuously questioned him in a small interview room and tape-recorded the exchange. The troopers did not inform Thompson of his Miranda rights. Although they constantly assured Thompson he was free to leave, they also told him repeatedly that they knew he had killed his former wife. Informing Thompson that execution of a search warrant was underway at his home, and that his truck was about to be searched pursuant to another warrant, the troopers asked questions that invited a confession. App. 43-79.1 Eventually, Thompson told the troopers he killed Dixie.
[104]*104As promised, the troopers permitted Thompson to leave, but impounded his truck. Left without transportation, Thompson accepted the troopers’ offer of a ride to his friend’s [105]*105house. Some two hours later, the troopers arrested Thompson and charged him with first-degree murder.
The Alaska trial court, without holding an evidentiary hearing, denied Thompson’s motion to suppress his September 15 statements. Tr. 118 (Dec. 12,1986); Tr. 142 (Mar. 18, 1987). Deciding the motion on the papers submitted, the trial court ruled that Thompson was not “in custody” for Miranda purposes, therefore the troopers had no obligation to inform him of his Miranda rights. App. 8-9.2 Applying an objective test to resolve the “in custody” question, the court asked whether “ ‘a reasonable person would feel he was not free to leave and break off police questioning.’” Id., at 7 (quoting Hunter v. State, 590 P. 2d 888, 895 (Alaska 1979)). These features, the court indicated, were key: Thompson arrived at the station in response to a trooper’s request; two unarmed troopers in plain clothes questioned him; Thompson was told he was free to go at any time; and he was not arrested at the conclusion of the interrogation. App. 7-8. Although the trial court held that, under the totality of the circumstances, a reasonable person would have felt free to leave, it also observed that the troopers’ subsequent actions — releasing and shortly thereafter arresting Thompson — rendered the question “very close.” Id., at 8-9.
After a trial, at which the prosecution played the tape-recorded confession, the jury found Thompson guilty of first-degree murder and tampering with evidence. The Court of Appeals of Alaska affirmed Thompson’s conviction, concluding, among other things, that the troopers had not placed Thompson “in custody,” and therefore had no obligation to give him Miranda warnings. Thompson v. State, [106]*106768 P. 2d 127,131 (Alaska App. 1989).3 The Alaska Supreme Court denied discretionary review. App. 24.
Thompson filed a petition for a writ of habeas corpus in the United States District Court for the District of Alaska. The District Court denied the writ, according a presumption of correctness under 28 U. S. C. § 2254(d) to the state court’s conclusion that, when Thompson confessed, he was not yet “in custody” for Miranda purposes. App. 37. The Court of Appeals for the Ninth Circuit affirmed without publishing an opinion. 34 F. 3d 1073 (1994). Based on Circuit precedent,4 the court held that “a state court’s determination that a defendant was not in custody for purposes of Miranda is a question of fact entitled to the presumption of correctness under 28 U. S. C. § 2254(d).” App. 41.
Federal Courts of Appeals disagree on the issue Thompson asks us to resolve: whether state-court “in custody” determinations are matters of fact entitled to a presumption of correctness under 28 U. S. C. § 2254(d), or mixed questions of law and fact warranting independent review by the federal habeas court. Compare Feltrop v. Delo, 46 F. 3d 766, 773 (CA8 1995) (applying presumption of correctness), with Jacobs v. Singletary, 952 F. 2d 1282, 1291 (CA11 1992) (conducting independent review). Because uniformity among federal courts is important on questions of this order, we granted certiorari to end the division of authority. 513 U. S. [107]*1071126 (1995). We now hold that the 28 U. S. C. § 2254(d) presumption does not apply to “in custody” rulings; accordingly, we vacate the Ninth Circuit’s judgment.
II
“[I]n-custody interrogation^],” this Court recognized in Miranda v. Arizona, place “inherently compelling pressures” on the persons interrogated. 384 U. S., at 467. To safeguard the uncounseled individual’s Fifth Amendment privilege against self-incrimination, the Miranda Court held, suspects interrogated while in police custody must be told that they have a right to remain silent, that anything they say may be used against them in court, and that they are entitled to the presence of an attorney, either retained or appointed, at the interrogation. Id., at 444. The Court defined “custodial interrogation” as “questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.” Ibid.; see also Oregon v. Mathiason, 429 U. S. 492, 495 (1977) (per curiam) (duty to give Miranda warnings is triggered “only where there has been such a restriction on a person’s freedom as to render him ‘in custody’ ”) (quoted in Stansbury v. California, 511 U. S. 318, 322 (1994) (per curiam)). Our task in petitioner Thompson’s case is to identify the standard governing federal habeas courts’ review of state-court “in custody” determinations.5
A
Section 2254 governs federal habeas corpus proceedings instituted by persons in custody pursuant to the judgment of a state court. In such proceedings, § 2254(d) declares, [108]*108state-court determinations of “a factual issue” “shall be presumed to be correct” absent one of the enumerated exceptions.6 This provision, added in a 1966 amendment, Act of [109]*109Nov. 2, 1966, Pub. L. 89-711, 80 Stat. 1105-1106, received the Court’s close attention in Miller v. Fenton, 474 U. S. 104 (1985). As the Miller Court observed, § 2254(d) “was an almost verbatim codification of the standards delineated in Townsend v. Sain, 372 U. S. 293 (1963), for determining when a district court must hold an evidentiary hearing before acting on a habeas petition.” Miller, 474 U. S., at 111.7 Townsend counseled that, if the habeas petitioner has had in state court “a full and fair hearing . . . resulting in reliable findings,” the federal court “ordinarily should . . . accept the facts as found” by the state tribunal. 372 U. S., at 318. Section 2254(d) essentially “elevated [the Townsend Court’s] exhortation into a mandatory presumption of correctness.” Miller, 474 U. S., at 111-112; see also id., at 112 (emphasizing respect appropriately accorded “a coequal state judiciary” and citing Culombe v. Connecticut, 367 U. S. 568, 605 (1961) (opinion of Frankfurter, J.)).
Just as Townsend’s instruction on the respect appropriately accorded state-court factfindings is now captured in the § 2254(d) presumption, so we have adhered to Townsend’s definition of the §2254(d) term “factual issue.”8 The Townsend Court explained that by “‘issues of fact,’” it meant [110]*110“basic, primary, or historical facts: facts ‘in the sense of a recital of external events and the credibility of their narrators ....’” 372 U. S., at 309, n. 6 (quoting Brown v. Allen, 344 U. S. 443, 506 (1953) (opinion of Frankfurter, J.)). “So-called mixed questions of fact and law, which require the application of a legal standard to the historical-fact determinations,” the Townsend Court added, “are not facts in this sense.” 372 U. S., at 309, n. 6.9 In applying § 2254(d), we have reaffirmed that “basic, primary, or historical facts” are the “factual issue[s]” to which the statutory presumption of correctness dominantly relates. See, e. g., Miller, 474 U. S., at 112 (“[Subsidiary factual questions” in alleged involuntariness of confession cases are subject to the § 2254(d) presumption, but “the ultimate question” — requiring a “totality of the circumstances” assessment — “is a matter for independent federal determination.”); Cuyler v. Sullivan, 446 U. S. 335, 342 (1980) (“mixed determination[s] of law and fact” generally are not subject to the § 2254(d) presumption of correctness).
It must be acknowledged, however, “that the Court has not charted an entirely clear course in this area.” Miller, 474 U. S., at 113. In regard to § 2254(d), as in other contexts,10 the proper characterization of a question as one of [111]*111fact or law is sometimes slippery. See ibid,.; Wainwright v. Witt, 469 U. S. 412, 429 (1985) (“It will not always be easy to separate questions of ‘fact’ from ‘mixed questions of law and fact’ for § 2254(d) purposes . . . .”). Two lines of decisions compose the Court’s § 2254(d) law/fact jurisprudence.
In several cases, the Court has classified as “factual issues” within §2254(d)’s compass questions extending beyond the determination of “what happened.” This category notably includes: competency to stand trial (e. g., Maggio v. Fulford, 462 U. S. 111, 117 (1983) (per curiam,)); and juror impartiality (e. g., Witt, 469 U. S., at 429; Patton v. Yount, 467 U. S. 1025, 1036 (1984); Rushen v. Spain, 464 U. S. 114, 120 (1983)). While these issues encompass more than “basic, primary, or historical facts,” their resolution depends heavily on the trial court’s appraisal of witness credibility and demeanor. See, e. g., Witt, 469 U. S., at 429 (Although the trial court is “applying some kind of legal standard to what [it] sees and hears,” its “predominant function in determining juror bias involves credibility findings whose basis cannot be easily discerned from an appellate record.”). This Court has reasoned that a trial court is better positioned to make decisions of this genre, and has therefore accorded the judgment of the jurist-observer “presumptive weight.” Miller, 474 U. S., at 114 (when an “issue involves the credibility of witnesses and therefore turns largely on an evaluation of demeanor, there are compelling and familiar justifications for leaving the process of applying law to fact to the trial court”).
On the other hand, the Court has ranked as issues of law for § 2254(d) purposes: the voluntariness of a confession (Miller, 474 U. S., at 116); the effectiveness of counsel’s assistance (Strickland v. Washington, 466 U. S. 668, 698 (1984)); and the potential conflict of interest arising out of an attorney’s representation of multiple defendants (Cuyler, 446 U. S., at 341-342). “What happened” issues in these cases warranted a presumption of correctness, but the Court declared “the ultimate question” outside §2254(d)’s domain [112]*112because of its “uniquely legal dimension.” Miller, 474 U. S., at 116; see also Sumner v. Mata, 455 U. S. 591, 597 (1982) (per curiam) (“[T]he constitutionality of the pretrial identification procedures used in this case is a mixed question of law and fact that is not governed by § 2254(d).”); Brewer v. Williams, 430 U. S. 387, 397, and n. 4, 403-404 (1977) (waiver of Sixth Amendment right to assistance of counsel is not a question of historical fact, but rather requires application of constitutional principles to facts).
B
The ultimate “in custody” determination for Miranda purposes, we are persuaded, fits within the latter class of cases. Two discrete inquiries are essential to the determination: first, what were the circumstances surrounding the interrogation; and second, given those circumstances,11 would a reasonable person have felt he or she was not at liberty to terminate the interrogation and leave. Once the scene is set and the players’ lines and actions are reconstructed, the court must apply an objective test to resolve “the ultimate inquiry”: “[was] there a ‘formal arrest or restraint on freedom of movement’ of the degree associated with a formal arrest.” California v. Beheler, 463 U. S. 1121, 1125 (1983) (per curiam) (quoting Mathiason, 429 U. S., at 495). The first inquiry, all agree, is distinctly factual. State-court findings on these scene- and action-setting questions attract a presumption of correctness under 28 U. S. C. § 2254(d). The second inquiry, however, calls for application of the controlling legal standard to the historical facts. This ultimate [113]*113determination, we hold, presents a “mixed question of law and fact” qualifying for independent review.
The practical considerations that have prompted the Court to type questions like juror bias and competency as “factual issue[s],” and therefore governed by § 2254(d)’s presumption of correctness, are not dominant here. As this case illustrates, the trial court’s superior capacity to resolve credibility issues is not dispositive of the “in custody” inquiry.12 Credibility determinations, as in the case of the alleged involuntariness of a confession, see Miller, 474 U. S., at 112, may sometimes contribute to the establishment of the historical facts and thus to identification of the “totality of the circumstances.” But the crucial question entails an evaluation made after determination of those circumstances: if encountered by a “reasonable person,” would the identified circumstances add up to custody as defined in Miranda?13 [114]*114See Berkemer v. McCarty, 468 U. S. 420, 442 (1984) (court must assess “how a reasonable man in the suspect’s position would have understood his situation”); cf. Miller, 474 U. S., at 116-117 (“ [Assessments of credibility and demeanor are not crucial to the proper resolution of the ultimate issue of ‘voluntariness.’ ”).
Unlike the voir dire of a juror, Patton, 467 U. S., at 1038, or the determination of a defendant’s competency, Maggio, 462 U. S., at 117, which “take[s] place in open court on a full record,” Miller, 474 U. S., at 117, the trial court does not have a first-person vantage on whether a defendant was “in custody” for Miranda purposes. See 474 U. S., at 117 (police interrogations yielding confessions ordinarily occur, not in court, but in an “inherently more coercive environment”). Furthermore, in fathoming the state of mind of a potential juror or a defendant in order to answer the questions, “Is she free of bias?,” “Is he competent to stand trial?,” the trial court makes an individual-specific decision, one unlikely to have precedential value.14 In contrast, “in custody” determinations do guide future decisions.15 We thus conclude [115]*115that once the historical facts are resolved, the state court is not “in an appreciably better position than the federal habeas court to make [the ultimate] determination” of the consistency of the law enforcement officer’s conduct with the federal Miranda warning requirement. See 474 U. S., at 117.
Notably, we have treated the “in custody” question as one of law when States complained that their courts had erroneously expanded the meaning of “custodial interrogation.” See Beheler, 463 U. S., at 1121-1125 (summarily reversing California Court of Appeal’s judgment that respondent was “in custody”); Mathiason, 429 U. S., at 494-496 (summarily reversing Oregon Supreme Court’s determination that respondent was “in custody”); cf. Oregon v. Hass, 420 U. S. 714, 719 (1975) (“[A] State may not impose ... greater restrictions [on police activity] as a matter of federal constitutional law when this Court specifically refrains from imposing them.”). It would be anomalous to type the question differently when an individual complains that the state courts had erroneously constricted the circumstances that add up to an “in custody” conclusion.
Classifying “in custody” as a determination qualifying for independent review should serve legitimate law enforcement interests as effectively as it serves to ensure protection of the right against self-incrimination. As our decisions bear out, the law declaration aspect of independent review potentially may guide police, unify precedent, and stabilize the law. See, e. g., Berkemer, 468 U. S., at 436-439 (routine traffic stop — typically temporary, brief, and public — does not place driver “in custody” for Miranda warning purposes); see also Monaghan, Constitutional Fact Review, 85 Colum. L. Rev. 229, 273-276 (1985) (“norm elaboration occurs best when the Court has power to consider fully a series of closely [116]*116related situations”; case-by-case elaboration when a constitutional right is implicated may more accurately be described as law declaration than as law application).
* * *
Applying §2254(d)’s presumption of correctness to the Alaska court’s “in custody” determination, both the District Court and the Court of Appeals ruled that Thompson was not “in custody” and thus not entitled to Miranda warnings. Because we conclude that state-court “in custody” determinations warrant independent review by a federal habeas court, the judgment of the United States Court of Appeals for the Ninth Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.