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Beckwith v. United States

Supreme Court of the United States · 1976 · Criminal Procedure

Criminal ProcedureMiranda warningsCustodial interrogationIRS investigationsMirandacustodycustodial interrogationfocus of investigation

Facts

Two IRS Intelligence Division special agents went to a private home where petitioner occasionally stayed and interviewed him about his federal income tax liability for 1966 through 1971. They identified themselves, stated that one of their functions was to investigate possible criminal tax fraud, and advised petitioner that he could not be compelled to answer incriminating questions, that his statements could be used against him, and that he could seek an attorney before responding. Petitioner said he understood his rights, spoke with the agents in what both sides described as a friendly and relaxed interview, and was not pressed on questions he chose not to answer. Later, after being told he was not required to furnish books or records, he provided records at his place of employment.

Issue

Must IRS special agents investigating possible criminal income tax violations give the full Miranda warnings during an interview with a taxpayer who is not in custody? More broadly, does the fact that the taxpayer is the focus of a criminal tax investigation make a noncustodial interview the functional equivalent of custodial interrogation?

Rule

Miranda applies to questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of freedom of action in a significant way. The focus of an investigation on a particular suspect, without custody or its equivalent, does not by itself trigger Miranda. Noncustodial questioning may still be challenged as involuntary if special circumstances show official conduct overbore the person's will, but that is a separate voluntariness inquiry.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Two investigators from the Fraud Enforcement Unit of the Treasury Department visit Lena Ortiz at her apartment in Phoenix at 9 a.m. They identify themselves, tell her they are examining whether her financial filings involved criminal fraud, and question her at her kitchen table for an hour. Lena is not arrested, the tone remains cordial, and she is free to move around the apartment.

If Lena later seeks to suppress her statements because she received no full Miranda warnings, what is the strongest argument for admitting the statements?

Explanation. The controlling rule is that Miranda applies only to custodial interrogation—questioning after a person has been taken into custody or otherwise significantly deprived of freedom of action. The majority rejected the idea that being the focus of a criminal investigation, standing alone, triggers Miranda in a noncustodial interview. Financial-crime investigations are not exempt, homes can in some circumstances involve custody, and disclosure of the criminal nature of the inquiry is not itself the constitutional test.