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Law School Case Brief

State v. Mangual - 311 Conn. 182, 85 A.3d 627 (2014)

Rule:

The clearest example of "custody" for purposes of Miranda occurs when a suspect has been formally arrested. As Miranda makes clear, however, custodial interrogation includes questioning initiated by law enforcement officers after a suspect has been arrested or otherwise deprived of his freedom of action in any significant way. Thus, not all restrictions on a suspect's freedom of action rise to the level of custody for Miranda purposes; in other words, the freedom-of-movement test identifies only a necessary and not a sufficient condition for Miranda custody. Rather, the ultimate inquiry is whether a reasonable person in the defendant's position would believe that there was a restraint on her freedom of movement of the degree associated with a formal arrest. Any lesser restriction on a person's freedom of action is not significant enough to implicate the core fifth amendment concerns that Miranda sought to address.

Facts:

After a trial in Connecticut superior court, a jury found defendant Ada Mangual guilty of possession of narcotics with the intent to sell by a person who was not drug-dependent in violation of General Statutes § 21a-278 (b), and possession of narcotics with the intent to sell within 1500 feet of a public school in violation of General Statutes § 21a-278a (b). Mangual had been arrested following a police investigation that culminated in the seizure of a quantity of heroin from Mangual's home pursuant to a duly authorized search warrant. The trial court rendered judgment in accordance with the jury verdict and imposed a total effective sentence of eight years' imprisonment. Mangual appealed, challenging, inter alia, the trial court's denial of her motion to suppress certain statements, claiming that those statements had been obtained in violation of her rights under the Fifth and Fourteenth Amendments to the United States Constitution when a police officer questioned her during the execution of the search warrant without first advising her of her Miranda rights. The appeals court affirmed the trial court's judgment, finding that the trial court properly determined that Mangual was not in "custody" for purposes of Miranda at the time of the police questioning and that, as a result, Miranda warnings were not required. On the granting of certification, Mangual appealed to the Supreme Court of Connecticut.

Issue:

Did the appellate court properly conclude that Mangual was not in custody for purposes of Miranda when a police officer interrogated her during the execution of a search warrant on her residence?

Answer:

No.

Conclusion:

The court reversed the appellate court's judgment and remanded the case to that court with direction to reverse the judgment of the trial court and to remand the case to that court for a new trial. The court agreed with Mangual that she was in "custody" at the time police officers questioned her during execution of the search warrant, and as such, the police were required to administer Miranda warnings prior to any questioning. Thus, the trial court erred by denying Mangual's motion to suppress the statements she made to police at that time. The court further ruled that, contrary to the State's contention, the admission of those statements into evidence at trial was not harmless beyond a reasonable doubt since the statements were the only direct and definitive evidence of Mangual's knowledge that the drugs were in the apartment.

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