Law School Case Brief
Mathis v. United States - 391 U.S. 1, 88 S. Ct. 1503 (1968)
Tax investigations are not immune from the Miranda requirements for warnings to be given a person in custody.
Mathis, who was in a state prison, was questioned by an Internal Revenue Service investigator about certain tax returns in a "routine tax investigation," without any warnings that any evidence he gave could be used against him, that he had a right to remain silent, and a right to counsel, or that one would be appointed for him if he was unable to afford counsel. Documents and oral statements obtained from Mathis were introduced in his criminal trial for filing false claims for tax refunds. He was convicted and his conviction was affirmed by the Court of Appeals.
Did the lower courts err in rejecting Mathis’ request for suppression of incriminating statements made to the Internal Revenue Service investigator during the course of their investigation into Mathis’ tax refunds?
Pursuant to Miranda v. United States, 384 U.S. 456 (1966), Mathis was entitled to warnings of his right to be silent and right to counsel. Tax investigations, which frequently lead to criminal prosecution, are not immune from the Miranda warning requirement to be given to a person in custody, whether or not such custody is in connection with the case under investigation. The Court held that the lower courts were in error by permitting the introduction of p Mathis’ self-incriminating evidence given without warning of his right to be silent and right to counsel.
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