## Facts

- Umar Farouk Abdulmutallab, a Nigerian citizen, attempted to detonate explosives concealed in his underwear while a passenger on a commercial flight traveling from Amsterdam to Detroit on December 25, 2009.
- Abdulmutallab ignited his clothing and part of the aircraft, but passengers subdued him and the fire was extinguished before the plane was destroyed.
- After the plane landed in Detroit, U.S. Customs and Border Protection officers met the flight and determined Abdulmutallab’s burns were serious; he was transported to the University of Michigan Hospital for treatment.
- At the hospital, Abdulmutallab received burn care and pain medication, including fentanyl administered in incremental doses during treatment.
- Later that day, FBI agents questioned Abdulmutallab at the hospital for about 50 minutes. During the interview, Abdulmutallab admitted possessing and attempting to use the explosives to blow up the plane and stated he acted on behalf of al-Qaeda.
- The agents did not provide *Miranda* warnings before the hospital questioning. According to the government, the agents believed there was a risk of additional imminent attacks and that immediate questioning was needed to protect public safety.
- Before trial, Abdulmutallab moved to suppress the hospital statements, arguing (1) the statements were involuntary given his injuries and medication and (2) the statements were obtained in violation of *Miranda* and were not saved by any exception.
- The United States argued the statements were voluntary and, even if *Miranda* applied, the public-safety exception recognized in *New York v. Quarles*, 467 U.S. 649 (1984), permitted the unwarned questioning.
- The district court (E.D. Mich.) held an evidentiary hearing on the suppression motion and issued a written opinion and order on September 16, 2011.

## Issues

1. Were Abdulmutallab’s statements to federal agents at the University of Michigan Hospital voluntary under the Due Process Clause, despite his burns, medical treatment, and pain medication?
2. Did the agents’ unwarned custodial questioning fall within *Quarles*’s public-safety exception to *Miranda*, making the pre-warning statements admissible?

## Decision

- The court **denied** Abdulmutallab’s motion to suppress his hospital statements.
- The court found Abdulmutallab’s statements were **voluntary**, crediting testimony that he was alert, oriented, and able to understand and respond appropriately during questioning despite his injuries and medication.
- The court held the hospital questioning fit within the **public-safety exception** to *Miranda* because agents faced an objectively reasonable concern about possible additional imminent attacks and asked questions to address that threat.
- **Disposition:** Motion to suppress statements made at the University of Michigan Hospital on December 25, 2009 was **denied**.

## Legal Principles

- A confession is involuntary under due process only when, under the totality of the circumstances, the defendant’s will was overborne and the statement was not the product of a rational intellect and free will.
- In assessing voluntariness, courts consider the defendant’s physical and mental condition (including pain and medication), the setting and duration of questioning, and whether law enforcement used coercive conduct.
- Routine medical treatment or the presence of pain medication does not automatically render a statement involuntary; the question is whether the defendant could understand the situation and make an uncoerced choice to speak.
- *Miranda* generally requires warnings before custodial interrogation, but *Quarles* recognizes a public-safety exception when officers have an objectively reasonable need to ask questions to protect the public from immediate danger.
- Under the public-safety exception, questions directed to locating or neutralizing an imminent threat may be asked without first giving warnings, and the resulting statements may be admitted.
- Trial courts may resolve suppression disputes through evidentiary hearings and credibility findings; when the court credits testimony showing lucidity and comprehension, it may find statements voluntary and admissible.

## Conclusion

In *United States v. Abdulmutallab*, the Eastern District of Michigan denied a pretrial motion to suppress statements Abdulmutallab made to FBI agents while receiving burn treatment at the University of Michigan Hospital after the attempted airline bombing. The court concluded the statements were voluntary under the totality of the circumstances and also admissible under *Quarles* because agents had an objectively reasonable need to ask immediate questions related to public safety without first administering *Miranda* warnings.


United States v. Abdulmutallab, 2011 WL 4345243, 2011 U.S. Dist. LEXIS 105462 (2011)