826 F.3d 450
7th Cir.2016Background
- FBI agents (unmarked cars, plain clothes, holstered guns) encountered Patterson at a public driveway and identified themselves as FBI; Patterson agreed to go to the FBI office to "clear his name.”
- Agents conducted a brief pat-down for officer safety, then Patterson voluntarily entered the agent’s car and was driven to the FBI office conference room on the 10th floor.
- The interview lasted about two hours in a conference room with unlocked interior exit handles; entry required card/keypad security that applied generally to the public/office.
- No Miranda warnings were given; agent Stewart intended to elicit incriminating statements and assured Patterson he would not be arrested that day; Patterson confessed to participating in the bank robbery.
- Patterson moved to suppress the statements as obtained in violation of Miranda; the district court denied the motion, he pleaded guilty but reserved the right to appeal the suppression ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Patterson was "in custody" for Miranda purposes during the FBI interview | Patterson: The move to the FBI office, locked-access doors, armed agents, pat-down, and two-hour private interview meant a reasonable person would not feel free to leave | Government: Patterson voluntarily agreed to go and speak, was never physically restrained or told he was under arrest, agents kept interaction low-key, and he left afterward | Not in custody; Miranda warnings not required |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required when custodial interrogation implicates Fifth Amendment)
- Oregon v. Mathiason, 429 U.S. 492 (1977) (stationhouse questioning not automatically custodial)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (Miranda applies only to custodial interrogation)
- Yarborough v. Alvarado, 541 U.S. 652 (2004) (custody inquiry uses objective reasonable-person test)
- J.D.B. v. North Carolina, 564 U.S. 261 (2011) (age can be relevant to custody analysis)
- Howes v. Fields, 565 U.S. 499 (2012) (consider all circumstances in custody analysis)
- Ambrose v. United States, 668 F.3d 943 (7th Cir. 2012) (review standard and custody factors)
- Lennick v. United States, 917 F.2d 974 (7th Cir. 1990) (formal arrest or equivalent restraint required for custody)
- Littledale v. United States, 652 F.3d 698 (7th Cir. 2011) (factors bearing on whether a reasonable person would feel free to leave)
- Podhorn v. United States, 549 F.3d 552 (7th Cir. 2008) (voluntary ride to interview mitigates custodial claim)
- Slaight v. United States, 620 F.3d 816 (7th Cir. 2010) (show of force and aggressive entry weigh toward custody)