United States v. Douglas Turner, 23-3519

Douglas Turner, an inmate already imprisoned for child pornography, was found in possession of a contraband cell phone in prison in 2017.
In May 2018, FBI and Bureau of Prisons investigators interviewed Turner about the cell phone; he was escorted to the interview but not restrained, and the agents were unarmed and in plain clothes.
During the interview, Turner was told he did not have to answer questions and was not in the interviewer’s custody.
Turner confessed to obtaining the phone from another inmate and using it to access child pornography.
Turner was indicted for possession of child pornography and moved to suppress his statements, alleging a Miranda violation.
The district court denied the suppression motion, finding the interview was noncustodial; Turner was convicted and appealed that ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Turner was in custody for Miranda purposes	Turner was effectively in custody and not Mirandized	The interview circumstances did not constitute custody	Not in custody for Miranda; suppression denied
Whether the interview environment was inherently coercive	Being escorted and interviewed under guard was coercive	Escorting was prison routine, not coercive interrogation	Prison context alone doesn’t create Miranda custody
Whether agent's demeanor or omissions undermined freedom	Agent never said Turner was free to leave; gentle demeanor disputed	Agent informed Turner he didn't have to answer; no deception	Agent's warnings sufficient; no compulsion found
Whether deception or strategy by the agent rendered it custodial	Non-disclosure of true investigative intentions amounted to compulsion	Investigator's private thoughts irrelevant if not communicated	No undue influence or compulsion; not custodial

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (sets rule requiring warnings during custodial interrogation)
Howes v. Fields, 565 U.S. 499 (U.S. 2012) (prisoners are not automatically in custody for Miranda)
Maryland v. Shatzer, 559 U.S. 98 (U.S. 2010) (distinction between prison routine restrictions and Miranda custody)
California v. Beheler, 463 U.S. 1121 (U.S. 1983) (defines custody as formal arrest or equivalent restraint)
United States v. Czichray, 378 F.3d 822 (8th Cir. 2004) (standard for whether custody exists for Miranda)
United States v. Hernandez, 281 F.3d 746 (8th Cir. 2002) (credibility findings nearly unreviewable on appeal)
United States v. Johnston, 353 F.3d 617 (8th Cir. 2003) (credibility and factual findings reviewed for clear error)