Hundreds of cases have grappled with the application of the United States Supreme Court's decision in Miranda v. Arizona. Many of those cases have dealt with the question of what constitutes "custodial interrogation" requiring "Miranda warnings" by law enforcement officers before statements elicited from a defendant may be used against him. In State v. McLean, the North Carolina Supreme Court held that, under the facts of that case, confronting a defendant with evidence against him does not constitute "interrogation." Therefore, statements made by the defendant properly were admitted against him even though he had not been advised of his rights under Miranda.
William M. Spivey, Constitutional Law - Confronting Accused with Evidence Against Him as "Interrogation" Within the Meaning of Miranda, 1 Campbell L. Rev. 173 (1979).