White v. United States
68 A.3d 271
D.C.2013Background
- Marquette Sharif White was pulled over while driving his 9-year-old son for an alleged obstruction (items hanging from the rearview mirror).
- Officers did not ask for license/registration or explain the stop; Officer Wright immediately ordered White out, handcuffed him, and led him to the rear of the vehicle near the cruiser.
- While handcuffed and separated from his son, Officer Wright asked if there was "anything illegal" in the car; White said he had a joint in his pants and produced it.
- White was charged with misdemeanor marijuana possession and moved to suppress his statements and the joint as elicited without Miranda warnings.
- The trial court denied the suppression motion; White entered a conditional guilty plea and appealed the Miranda ruling.
- The D.C. Court of Appeals held that, under the totality of the circumstances, a reasonable person in White’s position would have felt custody to a degree associated with formal arrest, so Miranda warnings were required and the statements should have been suppressed; the case was remanded to permit withdrawal of the plea.
Issues
| Issue | White's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether White was in Miranda custody when questioned | Handcuffing, removal from car, isolation from son, no explanation made a reasonable person feel not free to leave | The encounter was a lawful Terry traffic stop and brief precautionary handcuffing, not custody requiring Miranda | Court held White was in Miranda custody and statements should have been suppressed |
| Whether Miranda protects statements made during a traffic stop | Miranda applies when interrogation occurs in custody regardless of offense severity | Traffic stops are presumptively noncustodial under Berkemer; no categorical Miranda rule for traffic stops | Court applied Berkemer but found this stop exceeded ordinary traffic-stop conditions and triggered Miranda |
| Relevance of Fourth Amendment Terry analysis to Fifth Amendment custody | Miranda custody is distinct from Fourth Amendment reasonableness; custody focuses on how a reasonable person would perceive restraint | Reasonableness and proper Terry measures (handcuffing for officer safety) show detention was not an arrest | Court reaffirmed Fourth and Fifth inquiries differ; lawful Terry measures do not automatically negate Miranda custody |
| Whether the physical fruits (joint) must be suppressed given Miranda violation | Suppress statements and derivative physical evidence | Government argued the stop was noncustodial; post-Patane implications raised but not briefed | Court suppressed the unwarned statements; did not decide suppression of physical evidence and remanded to allow plea withdrawal |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (requires warnings when suspect is in custody and under interrogation)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (ordinary traffic stops are presumptively noncustodial but may become custodial under totality-of-circumstances)
- In re I.J., 906 A.2d 249 (D.C. 2005) (Miranda custody assessed by how a reasonable person in suspect’s position would perceive the situation)
- Thompson v. Keohane, 516 U.S. 99 (1995) (custody inquiry centers on whether a reasonable person would feel free to terminate the interrogation and leave)
- In re D.W., 989 A.2d 196 (D.C. 2010) (totality-of-circumstances approach to Miranda custody)
- United States v. Clemons, 201 F. Supp. 2d 142 (D.D.C. 2002) (driver removed, handcuffed, and restrained was deemed in custody)
- United States v. Patane, 542 U.S. 630 (2004) (Fifth Amendment does not necessarily require suppression of physical fruits of voluntary unwarned statements)