Facts
- A state police officer investigated a residential burglary; the victim identified Carl Ray Mathiason as a possible suspect because he was a parolee and associated with her son.
- After unsuccessful attempts to reach Mathiason, the officer left a note asking him to call.
- Mathiason called and agreed to meet the officer at the state patrol office near his apartment.
- The officer met Mathiason in a hallway, shook hands, took him to an office, told him he was not under arrest, and closed the door; they sat across a desk.
- The officer stated he believed Mathiason was involved, suggested truthfulness could be considered by prosecutors or the judge, and falsely claimed fingerprints had been found.
- After a few minutes, Mathiason admitted taking the property and gave a taped confession.
- The interview lasted about 30 minutes; Mathiason left the station without restraint and was arrested later.
- At a bench trial for first-degree burglary, the confession was admitted over a Miranda-based suppression motion; the trial court found Mathiason was not in custody. The intermediate appellate court affirmed, but the state supreme court reversed on the theory that the interview occurred in a “coercive environment.”
Issues
- Whether a suspect who voluntarily comes to a police station, is told he is not under arrest, is questioned in a closed office, confesses, and then leaves freely is “in custody” or otherwise significantly deprived of freedom so that Miranda warnings are required.
Decision
- The Supreme Court reversed and remanded.
- The Court held Mathiason was not in custody and was not otherwise significantly deprived of freedom of action.
- Because the interview was noncustodial, the failure to give Miranda warnings did not require suppression of the confession.
Legal Principles
- Miranda applies only to custodial interrogation: questioning initiated after a person is taken into custody or otherwise significantly deprived of freedom of action.
- A generally “coercive” setting, standing alone, does not make questioning custodial; most police interviews of suspects carry some pressure.
- A voluntary station-house interview is not custodial where the suspect is informed he is not under arrest, the encounter is brief, and the suspect leaves without hindrance.
- Police deception or implied consequences of “truthfulness” may bear on voluntariness in other contexts, but does not itself establish Miranda custody absent a significant restraint on freedom of movement.
Conclusion
The Court held that Miranda warnings were not required because the interview was a voluntary, brief station-house encounter in which Mathiason was told he was not under arrest and was free to leave, so his confession was not subject to suppression on Miranda grounds.