United States v. Schaffer
Facts
After a minor reported that Schaffer lured her to his New Jersey office with a job offer and sexually assaulted her, HSI agents executed a search warrant at his office and interviewed him for about an hour. The agents told Schaffer he was not under arrest, did not handcuff or physically restrain him, did not draw weapons, and allowed him to drink coffee and smoke cigarettes, but they denied his requests to leave during the ongoing search because evidence boxes blocked the threshold and leaving would create a security issue. Schaffer then made incriminating statements, and only after the interview and review of the evidence was he arrested and given Miranda warnings. A later forensic search uncovered four videos showing Schaffer sexually assaulting two other minor girls, and the district court admitted limited excerpts at trial under Rule 413 after conducting Rule 403 balancing.
Issue
Whether Schaffer was in custody for Miranda purposes during the office interview such that his pre-warning statements should have been suppressed. Whether Federal Rule of Evidence 413 facially violates the Fifth Amendment Due Process Clause by permitting propensity evidence in sexual-assault prosecutions. Whether the district court abused its discretion under Rule 403 by admitting excerpts from four videos of Schaffer's prior sexual assaults.
Rule
A suspect is in custody for Miranda purposes only when, considering all the surrounding circumstances objectively, a reasonable person would both not feel free to leave and would understand his freedom of action to be curtailed to a degree associated with formal arrest. Rule 413 permits admission of other sexual assaults in sexual-assault prosecutions, and because Rule 403 applies to such evidence, Rule 413 creates only a presumption that the evidence is relevant and probative, not automatic admissibility. Relevant evidence must be excluded under Rule 403 only when its probative value is substantially outweighed by a danger of unfair prejudice.
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Before trial, Nolan moves to suppress his statements because he was questioned without Miranda warnings. What is the best argument against suppression?