Com. v. El-Amin, A., 1881 EDA 2023

Abdullah I. El-Amin was convicted by a jury of third-degree murder and possessing an instrument of crime following the fatal shooting of Ms. Green during an alleged transaction in his car.
Police initially stopped El-Amin for disregarding a stop sign and discovered a gunshot victim in his vehicle; El-Amin provided a false account of the incident to police.
At both the traffic stop and hospital, officers asked El-Amin questions about the location and circumstances of the shooting before El-Amin was Mirandized.
El-Amin later gave a recorded statement at the homicide division, post-Miranda, in which he admitted to shooting the victim, claiming self-defense.
The trial court denied El-Amin’s motion to suppress his pre-Miranda statements, finding he was not in custody or subject to interrogation at those times, and ultimately sentenced him to consecutive terms of imprisonment.
On appeal, El-Amin challenged only the denial of suppression of his statements made prior to receipt of Miranda warnings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Suppression of Pre-Miranda Statements	El-Amin: He was in custody and interrogated; Miranda warnings required at scene/hospital.	Commonwealth: El-Amin was not in custody or interrogated; no warnings required.	No Miranda violation; suppression denied.
Admissibility of Post-Miranda Statement	El-Amin: (Not directly argued on appeal; claim waived)	Commonwealth: Statement given after valid Miranda waiver.	Argument waived/not preserved; no suppression.

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation)
Stansbury v. California, 511 U.S. 318 (1994) (Defines custody for Miranda as formal arrest or its equivalent)
Rhode Island v. Innis, 446 U.S. 291 (1980) (Defines interrogation for Miranda purposes)
Commonwealth v. Pakacki, 901 A.2d 983 (Pa. 2006) (Miranda applies only to custodial interrogation)
Commonwealth v. Williams, 640 A.2d 1251 (Pa. 1994) (Totality of circumstances analysis for custodial status)