Facts
- A Providence taxi driver was robbed by an assailant armed with a sawed-off shotgun; the driver identified Thomas J. Innis from a photograph.
- Police arrested Innis on the street and advised him of his Miranda rights; additional officers repeated the warnings.
- Innis stated he understood his rights and requested to speak with a lawyer.
- Officers transporting Innis in a patrol car were instructed not to question or intimidate him.
- During the ride, two officers discussed the missing shotgun between themselves, mentioning a nearby school and expressing concern that handicapped children might find the weapon and be injured.
- Innis interrupted, asked officers to return to the arrest area, and offered to show them where the shotgun was located.
- After renewed Miranda warnings, Innis led police to the shotgun and stated he wanted it removed because of the children in the area.
Issues
- Whether officers “interrogated” Innis under Miranda by conversing about the missing shotgun in his presence after he invoked his right to counsel.
- Whether Innis’s statements and the recovered shotgun should be suppressed as the product of custodial interrogation without a valid waiver.
Decision
- The Supreme Court reversed the state high court and held that Innis was not “interrogated” within the meaning of Miranda.
- The Court defined Miranda “interrogation” as (1) express questioning or (2) its functional equivalent: police words or actions (other than those normally attendant to arrest and custody) that police should know are reasonably likely to elicit an incriminating response.
- Applying that test, the Court treated the officers’ remarks as brief, offhand comments not reasonably foreseeable to prompt an incriminating response from Innis.
- Because Innis’s response was treated as volunteered rather than elicited through interrogation, his statements and the shotgun were admissible.
Legal Principles
- Miranda safeguards apply to custodial “interrogation,” meaning express questioning or the functional equivalent.
- The “functional equivalent” inquiry is objective and focuses on what police should have known was reasonably likely to elicit an incriminating response, with attention to the suspect’s perceptions.
- Conduct “normally attendant to arrest and custody” does not, without more, constitute interrogation.
- Volunteered statements not prompted by interrogation are admissible even after a suspect invokes the right to counsel, so long as they are not the product of prohibited custodial interrogation.
Conclusion
The Court limited Miranda’s reach by holding that not all police remarks in a suspect’s presence amount to interrogation, and it adopted the objective “reasonably likely to elicit an incriminating response” test for determining when police conduct is the functional equivalent of questioning.