Law School Case Brief
Oregon v. Mathiason - 429 U.S. 492, 97 S. Ct. 711 (1977)
Police officers are not required to administer Miranda warnings to everyone whom they question. Nor is the requirement of warnings to be imposed simply because the questioning takes place in the station house, or because the questioned person is one whom the police suspect. Miranda warnings are required only where there is such a restriction on a person's freedom as to render him in custody.
A police officer investigating a burglary, after being informed by the victim that she suspected defendant Carl Mathiason, who was then on parole, left his card at Mathiason's apartment with a note asking him to call the officer so that the officer could discuss something with him. Shortly thereafter, Mathiason called the officer who then suggested that Mathiason meet with him at a state patrol office close to Mathiason's apartment. Upon Mathiason's arrival at the office, the officer took Mathiason into a room, told him that he was not under arrest, closed the door, and informed Mathiason of his belief that he had been involved in the burglary. After the officer falsely stated that Mathiason's fingerprints had been found at the burglary scene, Mathiason, within five minutes after coming to the office, confessed to the burglary. The officer then advised Mathiason of his Miranda rights and took a taped confession. At the end of the taped conversation, about one-half hour after he had come to the office, Mathiason left upon being informed that he was not being arrested but that the case was being referred to the district attorney. Subsequently, at trial in Oregon state court, Mathiason filed a motion to suppress his confession as the fruit of questioning not preceded by Miranda warnings. Mathiason was convicted of first degree burglary. On Mathiason's appeal, an appellate court affirmed. On further appeal, the Supreme Court of Oregon reversed, finding that although Mathiason had not been arrested or otherwise formally detained, because he was in a police station behind closed doors, and told that his fingerprints were found at the scene, the interrogation had taken place in a coercive environment requiring Miranda warnings. The State was granted a writ of certiorari.
Was the interrogation of Mathiason violative of his Miranda rights?
The Supreme Court of the United States reversed the state supreme court judgment that reversed Mathiason's conviction and remanded the case for further proceedings. The Court found that because Mathiason had come voluntarily to the station, he was seated at a desk, he was told that he was free to go, and because he did in fact leave at the conclusion of a 30 minute interview, no Miranda violation occurred. The Court found that no custody was proven, thus Miranda was not applicable. The Court stated that such noncustodial situations were not converted into Miranda situations just because the questioning took place in a coercive environment. The Court further stated that police officers were not required to administer Miranda warnings to every person that they questioned, nor to everyone who came to the station house for an interview. Miranda only applied in those situations where the person was in custody.
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