United States v. Cavazos
2012 U.S. App. LEXIS 1103
| 5th Cir. | 2012Background
- Government sought suppression of Cavazos's pre-Miranda statements after a morning home search with ~14 officers; Cavazos was awakened, handcuffed, separated from family, and questioned for over an hour in his son's bedroom without Miranda warnings.
- Interrogation occurred after Cavazos was identified, detained during the entry, and monitored during bathroom and clothing searches; Cavazos was told the interview was non-custodial but remained under police presence and control.
- Cavazos allowed to speak on the phone but the agents listened in, and Cavazos wrote a statement under agent supervision before formal arrest and Miranda rights were read.
- District court granted suppression of the statements, finding custodial interrogation; Government appealed under 18 U.S.C. § 3731.
- Court reviews custody and voluntariness under the totality of circumstances, applying a deferential standard to the district court’s factual findings and de novo review of law.
- Court affirms the district court, holding Cavazos was in custody for Miranda purposes during the questioning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Cavazos in custody for Miranda purposes during the interview? | Government contends Cavazos was not in custody. | Cavazos argues the environment and restraint constituted custody. | Yes, Cavazos was in custody. |
| Did the non-custodial labeling negate the need for Miranda warnings? | Government argues the label controls; in-home setting less coercive. | Cavazos argues the totality of circumstances show coercion despite label. | Label alone insufficient; totality shows custody. |
Key Cases Cited
- United States v. Bengivenga, 845 F.2d 593 (5th Cir. 1988) (custody requires restraint beyond ordinary seizure; totality of circumstances)
- J.D.B. v. North Carolina, 131 S. Ct. 2394 (U.S. 2011) (age and perceptions affect custody determination under totality of circumstances)
- California v. Beheler, 463 U.S. 1121 (1983) (Miranda custody analysis uses totality of circumstances)
- United States v. Hargrove, 625 F.3d 170 (4th Cir. 2010) (in-home interrogation can be custodial depending on coercive environment)
- United States v. Fike, 82 F.3d 1315 (5th Cir. 1996) (presence of many officers can weigh toward custodial influence)
- United States v. Perrin, 659 F.3d 718 (8th Cir. 2011) (statement of freedom to leave affects custody analysis)
- United States v. Craighead, 539 F.3d 1073 (9th Cir. 2008) (in-home interrogation may be custodial based on police-dominated atmosphere)
- Beheler (cited within Beheler), 463 U.S. 1121 (1983) (Miranda custody analysis via totality of circumstances)