United States v. Thomas Saylor, 705 F. App'x 369

FBI investigated Thomas Saylor (registered sex offender) for alleged possession and distribution of child pornography based on tips and email/subpoena evidence.
On March 27, 2014, agents executed a federal search warrant at a Louisville halfway house where Saylor lived; roughly 10 agents participated and residents were initially handcuffed for safety.
Saylor was identified in a hallway, asked to speak with agents, and voluntarily went to the kitchen where an agent monitored him while he waited. He was not handcuffed or told he was under arrest.
FBI interviewers (two officers) conducted a 15–30 minute interview in the open-door kitchen without giving Miranda warnings or telling Saylor he could leave; Saylor made incriminating admissions and initialed printed images.
After the interview, Saylor’s probation officer—who had been informed of the confession—immediately placed Saylor under arrest; subsequent warrants yielded extensive child-pornography files.
Saylor moved to suppress his statements as the product of custodial interrogation; the magistrate and district court denied suppression, he pled guilty reserving appeal, and was sentenced to 300 months. Appellate court reviews custody de novo (facts for clear error).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Saylor was "in custody" for Miranda at the halfway-house interview	Saylor: halfway-house status, heavy police presence, monitoring, and lack of Miranda or being told he could leave made the interview custodial	Government: interview occurred in Saylor’s home (noncustodial), he was not physically restrained or arrested, interview was short and conversational, and he voluntarily consented to speak	Court held Saylor was not in custody for Miranda; suppression denial affirmed

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings requirement for custodial interrogation)
Oregon v. Mathiason, 429 U.S. 492 (1977) (Miranda does not apply to noncustodial questioning)
J.D.B. v. North Carolina, 564 U.S. 261 (2011) (custody is an objective inquiry comparing restraint to formal arrest)
Thompson v. Keohane, 516 U.S. 99 (1995) (custody determination asks whether freedom of movement was restrained to degree associated with formal arrest)
United States v. Panak, 552 F.3d 462 (6th Cir. 2009) (factors for custody inquiry: location, length/manner, freedom of movement, and warnings)
Stansbury v. California, 511 U.S. 318 (1994) (focus on objective circumstances of interrogation for custody analysis)
United States v. Salvo, 133 F.3d 943 (6th Cir. 1998) (home interviews can be noncustodial; suspect-chosen locations weigh against custody)
United States v. Craighead, 539 F.3d 1073 (9th Cir. 2008) (contrasting Ninth Circuit factors finding custodial interview in home search setting)
United States v. Brobst, 558 F.3d 982 (9th Cir. 2009) (discusses confronting suspect with evidence as factor in custody analysis)