The police suspected the defendant had information concerning a murder. They placed an undercover officer in a jail cellblock with the defendant when he was incarcerated on unrelated charges. The officer engaged the defendant in conversation about plans to escape. When the officer asked him if he had ever killed anyone, the defendant made inculpatory statements implicating himself in the murder. The defendant was then charged with the murder. The defendant filed a motion to suppress the statements because the officer had not provided him Miranda warnings.
Whether the officer must provide a suspect in custody Miranda warnings if the suspect does not know the officer represents the government?
No. Miranda warnings only apply to the police-dominated environment in which a known police officer controls the conditions.
The Miranda doctrine must be strictly enforced, but only in situations where the concerns underlying that decision are present (i.e., a government-dominated atmosphere whereby the suspect may feel compelled to speak by the fear of reprisal or in the hope of more lenient treatment should he confess). That coercive atmosphere is not present when an incarcerated person speaks freely to someone whom he believes to be a fellow inmate. In such circumstances, Miranda does not forbid mere strategic deception by taking advantage of a suspect’s misplaced trust. The Miranda warnings were not meant to protect suspects from boasting about their criminal activities in front of persons whom they believe to be their cellmates. Note that Massiah v. United States, which held that the government could not use an undercover agent to circumvent the Sixth Amendment right to counsel once a suspect has been charged, is inapplicable here since no murder charges had been filed at the time of the interrogation (the Sixth Amendment had not attached).
Coercion is determined from the perspective of the suspect. The inherent coerciveness of custodial interrogation is not present when the target is unaware that he is talking with authorities. Miranda is not concerned with ploys to mislead a suspect or lull him into a false sense of security that do not rise to the level of compulsion or coercion to speak.
496 U.S. 292, 110 S. Ct. 2394 (1990)