## Facts

- A Lansing, Michigan police officer observed Jermaine Byron Woods speeding in a red Pontiac and approached after the vehicle parked in a residential lot.
- As Woods exited, the officer activated overhead lights and ordered Woods to re-enter the car and place his hands on the steering wheel.
- Woods initially failed to comply and repeatedly reached down toward the passenger side, prompting the officer to draw his firearm; Woods then complied.
- The officer removed Woods and conducted a lawful patdown incident to arrest.
- During the patdown, the officer felt a hard lump in Woods’s pocket and, without providing Miranda warnings, asked, “What is in your pocket?”
- Woods replied that it was “my weed,” and the officer recovered a bag of marijuana.
- A subsequent search of the car uncovered crack cocaine and a firearm, leading to charges for drug trafficking and possession of a firearm in furtherance of a drug-trafficking crime.

## Issues

1. Whether asking “What is in your pocket?” during a lawful patdown incident to arrest constituted custodial interrogation requiring Miranda warnings.
2. If Miranda was violated, whether Woods’s statement and the later-discovered drugs and firearm had to be suppressed as fruits of the violation.

## Decision

- The Sixth Circuit affirmed the denial of Woods’s motion to suppress and affirmed the conviction.
- The court held the officer was not required to give Miranda warnings before asking the single question after feeling an unexplained hard object during a lawful patdown incident to arrest.
- Because there was no Miranda violation, suppression of the statement or physical evidence was unwarranted.

## Legal Principles

- Miranda applies only to custodial interrogation, not to every question posed to a person in custody.
- A brief, limited question asked during a lawful frisk or patdown—aimed at clarifying the nature of an unknown object that could pose an immediate safety risk—may fall outside Miranda’s concept of interrogation.
- The “interrogation” inquiry considers whether questioning is reasonably likely to elicit an incriminating response, evaluated in context, including whether the questioning is coercive, prolonged, or investigative.

## Conclusion

The court held that a single, safety-oriented question posed during a lawful patdown incident to arrest about an unknown hard object did not amount to custodial interrogation under Miranda, so Woods’s response and the resulting evidence were not suppressed.


United States v. Woods, 711 F.3d 737 (6th Cir. 2013)