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Orozco v. Texas

Supreme Court of the United States · 1969 · Criminal Procedure

Criminal ProcedureMirandaSelf-IncriminationCustodial InterrogationFifth AmendmentSelf-Incrimination ClauseMiranda warningscustody

Facts

After a fatal shooting outside a Dallas cafe, petitioner returned to his boardinghouse and went to sleep. At about 4 a.m., four police officers entered his bedroom and questioned him; according to one officer, from the moment petitioner gave his name he was under arrest and not free to go where he pleased. Without first giving warnings about the right to remain silent, the right to counsel, or appointed counsel, officers asked whether he had been at the restaurant and whether he owned a pistol, and petitioner admitted both and stated the gun was in a washing machine. Ballistics tests linked that gun to the fatal shot, and an officer testified to petitioner's statements at trial over objection.

Issue

Does Miranda apply when police interrogate a suspect in his own bedroom rather than at the police station, where the suspect is under arrest and not free to leave? If so, may the State use statements obtained without Miranda warnings during that custodial questioning?

Rule

Miranda warnings are required whenever officers interrogate a person who is in custody or otherwise deprived of freedom of action in any significant way, whether at the police station or elsewhere. Statements obtained through custodial interrogation without those warnings may not be used by the State because their use violates the Fifth Amendment's Self-Incrimination Clause as construed in Miranda.

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

At 3:30 a.m. in Phoenix, four detectives entered Lena Ortiz's apartment with the landlord's permission, woke her, and stood around her bed. One detective testified that from the moment Lena identified herself, she was under arrest and would not have been allowed to leave. Without giving any warnings, the detectives asked whether she had been near a nightclub stabbing and whether she still had the folding knife she carried earlier that evening; Lena answered both questions.

If the prosecution offers Lena's answers at trial, how should the court rule?

Explanation. The majority rule is that Miranda applies whenever officers interrogate a person who is in custody or otherwise significantly deprived of freedom, whether at the station or elsewhere. Familiar surroundings do not eliminate custody. Because Lena was under arrest and not free to leave when officers asked incriminating questions, her unwarned answers are inadmissible.