United States v. Richardson, 2014 U.S. Dist. LEXIS 50905

Early-morning execution of a search warrant at Richardson’s D.C. apartment by ~14 FBI/MPD officers; forced entry with guns drawn; occupants (Richardson and William Hill) were handcuffed and seated in living room while officers searched.
Warrant targeted Hill; officers found a .38-caliber pistol in a purse in a laundry basket about 20 minutes into the search.
Richardson was handcuffed in the living room, later escorted to the bathroom by Detective Quigley (female, masked); Quigley removed Richardson’s handcuffs and stood inside the closed bathroom while Richardson used the facilities.
While alone with Quigley in the bathroom, Richardson spontaneously said the gun was hers; Quigley returned with Agent Ray and Richardson reiterated the admission; officers then questioned her briefly and she repeated ownership twice more.
Richardson was unrestrained when returned to living room; about 15 minutes later officers decided to arrest her; Miranda warnings were given at time of arrest, not at the time of the earlier statements.
Richardson moved to suppress the three bathroom statements as products of custodial interrogation under Miranda v. Arizona; the court held an evidentiary hearing and found Richardson was in custody but her statements were voluntary and not the product of interrogation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Richardson was "in custody" for Miranda when she made the bathroom statements	Government conceded custody for the 2nd and 3rd statements and argued a reasonable person would not feel targeted before the first statement (focus was on Hill)	Richardson argued she was detained throughout (forced entry, weapons drawn, handcuffed, officer present) and therefore in custody for all statements	Court: Richardson was in custody when she first spoke (objective totality of circumstances showed a reasonable person would not feel free to leave)
Whether statements were "interrogation" (i.e., police words/actions reasonably likely to elicit incriminating response)	Government: officers’ conduct and words were not reasonably likely to elicit incriminating responses; initial admission was volunteered and later statements came after encouragement to retract, not to elicit confession	Richardson: her admissions were not voluntary responses but the product of custodial interrogation and thus required Miranda warnings	Court: No interrogation — statements were volunteered; later questions sought clarification or urged her not to claim ownership for Hill’s benefit, so warnings were not required; statements admissible

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes warnings requirement for custodial interrogation)
Rhode Island v. Innis, 446 U.S. 291 (1980) (defines "interrogation" to include words or actions police should know are reasonably likely to elicit incriminating response)
Thompson v. Keohane, 516 U.S. 99 (1995) (objective test for custody: would a reasonable person feel free to terminate the encounter and leave)
Stansbury v. California, 511 U.S. 318 (1994) (custody determination focuses on objective circumstances)
Muehler v. Mena, 544 U.S. 93 (2005) (detention during a search warrant execution can be lawful under Fourth Amendment and may or may not be Miranda custody)
United States v. Brinson-Scott, 714 F.3d 616 (D.C. Cir.) (2013) (detention during execution of a warrant may constitute Miranda custody)
United States v. Peterson, 506 F. Supp. 2d 21 (D.D.C. 2007) (handcuffing and forcible entry during a search can support a finding of Miranda custody)
United States v. Savoy, 889 F. Supp. 2d 78 (D.D.C. 2012) (similar facts: forcible entry and handcuffing during a warrant execution can create custodial environment)
Bosley v. United States, 426 F.2d 1257 (D.C. Cir. 1970) (volunteered/spontaneous statements are admissible without Miranda warnings)
United States v. Sheffield, 821 F. Supp. 2d 351 (D.D.C. 2011) (analysis of interrogation and objective inquiry into whether police questioning was likely to elicit incriminating responses)