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Oregon v. Mathiason

Supreme Court of the United States · 1977 · Criminal Procedure

Criminal ProcedureMirandaCustodial InterrogationMirandacustodial interrogationpolice station questioningfreedom to departnoncustodial interview

Facts

A state police officer investigating a burglary left his card at Mathiason's apartment asking him to call, and Mathiason later voluntarily called and agreed to meet at the state patrol office. At the office, the officer told Mathiason he was not under arrest, closed the office door, said he wanted to discuss a burglary, and falsely stated that Mathiason's fingerprints were found at the scene. Within about five minutes, Mathiason admitted taking the property, after which the officer gave Miranda warnings and obtained a taped confession. At the end of the half-hour interview, the officer told Mathiason he was not being arrested and Mathiason left the office without hindrance.

Issue

Whether Miranda warnings were required before questioning Mathiason at the police station when he came voluntarily, was told he was not under arrest, and was allowed to leave after the interview. More specifically, the question was whether this interview was custodial interrogation because it occurred in a supposedly coercive environment.

Rule

Miranda applies only to custodial interrogation, meaning 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. A noncustodial interview does not become custodial merely because it occurs at a police station, because the person questioned is a suspect, because the setting has coercive aspects, or because police use a false statement during questioning.

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

In Columbus, Ohio, Detective Lena Ortiz left a message asking Devin Cole to call her about a warehouse theft. Devin called back, agreed to meet at the city safety building, was told at the start of the interview that he was not under arrest, sat with Ortiz in a closed office for 25 minutes, admitted involvement, and then walked out without interference.

Were Miranda warnings required before Devin's admission?

Explanation. Miranda applies only to custodial interrogation, meaning questioning after a person has been taken into custody or otherwise deprived of freedom of action in a significant way. Under the majority opinion, station-house questioning alone does not create custody. Because Devin came voluntarily, was expressly told he was not under arrest, and in fact left without hindrance, the interview was noncustodial and warnings were not required before the admission.