The IRS was investigating the defendant for tax fraud. Two IRS agents met with the defendant in a private home where he sometimes stayed. One of the agents testified that they went to see the defendant at this residence at approximately 8:00 a.m. in order to spare him the possible embarrassment of being interviewed at his place of employment, which opened at 10:00 a.m. Upon arrival, the agents were invited into the house and, when the defendant entered the room, they introduced themselves. The defendant excused himself for a period of approximately five minutes to finish dressing. When he returned, the three sat at a dining room table where the agents presented their credentials, informed the defendant of why they wanted to speak with him, and read him some, but not all, of his Miranda warnings. The defendant acknowledged that he understood his rights and the agents interviewed him until approximately 11:00 a.m. The agents described the conversation as “friendly” and “relaxed,” while the defendant noted that the agents did not “press” him on any question he could not or chose not to answer. Before ending the interview, the agents requested permission to examine certain records. When the defendant indicated the records were maintained at his place of employment, the agents asked if they could meet him there later. The agents met him approximately 45 minutes later at his place of employment. The senior agent advised the defendant that he was not required to furnish any books or records, but the defendant supplied the books to the agents nonetheless. Prior to trial, the defendant moved to suppress all of the statements made to the agents and any evidence obtained as a result of those statements on the grounds that he was in custody at the time of the interview and had not been fully advised of his Miranda warnings.
Whether the defendant was in custody at the time of the interview?
No. The defendant could not have reasonably believed he was in custody at the time of the interview.
Miranda warnings are necessary whenever law enforcement officers question an individual who has been “taken into custody or otherwise deprived of his freedom of action in any significant way.” The defendant was neither arrested nor detained against his will by the agents. While he was clearly the “focus” of the agents’ investigation, “he hardly found himself in the custodial situation described by the Miranda Court as the basis for its holding.” The agents were not required to read him his Miranda warnings, and any statements he made and any evidence derived from those statements were admissible against him at his later trial.