United States v. James Wells, 14-30146

James Michael Wells, a Coast Guard COMMSTA employee, was interviewed by agents on April 12 and again on April 13, 2012; excerpts from those interviews were introduced at trial.
On April 12 the base had been locked down and COMMSTA employees were ordered to remain available for questioning; interviews were conducted at the workplace by two plain-clothes agents with concealed weapons.
Wells was not physically restrained, handcuffed, or touched; interviews on April 12 were non-accusatory, cordial, and short (intermittent, cumulatively under roughly an hour).
Wells was allowed to talk to coworkers between interviews and was permitted to leave the base at the end of the day; he was Mirandized on April 13 before a later interview.
Procedurally: Wells moved to suppress pre-Miranda statements (and raised an involuntariness/Garrity claim for the first time on appeal); the district court denied suppression and the Ninth Circuit reviewed de novo and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment – Was Wells "seized" on April 12?	Wells: being ordered to remain on a locked-down base and kept under USCG command made the interrogation a seizure.	Government: Wells voluntarily reported; interviews were consensual, noncoercive, no physical restraint or aggressive conduct.	No seizure; even if so, detention was reasonable given government interests, so Fourth Amendment challenge fails.
Fifth Amendment – Were Miranda warnings required on April 12 (was Wells "in custody")?	Wells: lockdown, orders to stay, and interrogation circumstances meant a reasonable person would not feel free to leave, so Miranda required.	Government: interviews were noncustodial fact-finding (cordial, familiar setting, short duration, ability to speak with others, no coercion).	Not in custody; no Miranda warnings required and pre-Miranda statements admissible.

Mendenhall v. United States, 446 U.S. 544 (examples of circumstances indicating a seizure)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation)
Aguilera v. Baca, 510 F.3d 1161 (employment/military context and when obedience to superior is a seizure)
United States v. Bassignani, 575 F.3d 879 (factors for custody determination; noncustodial two‑and‑a‑half hour interview analysis)
United States v. Kim, 292 F.3d 969 (custody test — formal arrest or restraint degree; five relevant factors)
United States v. Hawkins, 249 F.3d 867 (reasonableness balancing for seizures less intrusive than arrest)
Florida v. Bostick, 501 U.S. 429 (consensual encounter standard)