United States v. Estrada - 430 F.3d 606 (2d Cir. 2005)

Rule:

Although statements made by a suspect in custody in response to police interrogation are typically inadmissible unless preceded by Miranda warnings, the United States Supreme Court has recognized a "public safety" exception to that rule. The Court has held that there is a "public safety" exception to the requirement that Miranda warnings be given before a suspect's answers to police questions may be admitted into evidence. The Court has characterized its holding as a "narrow exception" to the Miranda rule, indicating that police officers can and will distinguish almost instinctively between questions necessary to secure their own safety or the safety of the public and questions designed solely to elicit testimonial evidence from a suspect.

Facts:

On February 5, 1997, officers executed an arrest warrant for defendant DeJesus. The warrant had been issued in connection with two probation violations, and the team was aware of DeJesus's criminal record, which included two assault convictions. As the officer was standing over and attempting to handcuff DeJesus, he said that he “got a gun in his pocket.” Having handcuffed DeJesus, Gonzalez found a gun and a quantity of heroin in the jacket pocket. At the conclusion of the suppression hearing, the district court denied DeJesus's motion, finding that the evidence had been seized pursuant to a valid search incident to a lawful arrest. The district court did not address DeJesus’s claim that the statements indicating the location of the gun should have been suppressed pursuant to Miranda, instead treating the motion as having raised only a Fourth Amendment claim.

Issue:

Under the circumstances, were the physical evidence, i.e., gun and heroin, products of an illegal custodian interrogation, and should have been suppressed?

Answer:

No.

Conclusion:

The Court held that the district court did not err by denying one defendant's motion to suppress statements and physical evidence challenged as the produce of an illegal custodial interrogation because the public safety exception applied, and therefore the statements and evidence was properly admitted. The officers had ample reason to fear for their safety, given defendant's assault convictions and an informant's statements that defendant kept drugs in the apartment. According to the Court, an officer's questions whether there were any guns in the apartment were narrow in scope, directly targeting the safety concern and were not posed to elicit incriminating evidence.