Mathis was serving a state prison sentence when an IRS agent questioned him about tax returns. Prior to questioning, the agent did not advise Mathis of his Miranda rights. Documents and oral statements obtained from Mathis during this interview were introduced at his criminal trial for filing false claims for tax refunds.
Whether Mathis’ statements to the IRS agent should have been suppressed. because Mathis was not advised of his Miranda rights.
Yes. Because Mathis was not advised of his Miranda rights, the lower courts improperly allowed the introduction of his incriminating statements.
The government claimed that Miranda warnings were not required because: (1) The questions were asked as part of a routine tax investigation that would not necessarily result in criminal charges; and (2) The defendant was not placed in jail by the officer questioning him, but was there for an entirely separate offense. The Court disagreed with both of these positions. First, while tax investigations “may be initiated for the purpose of civil action rather than criminal prosecution,” these investigations frequently lead to criminal prosecutions, just as occurred here. Thus, “routine tax investigations” still require that Miranda warnings be given to a person in custody. Second, the reason the defendant was in custody was irrelevant for Miranda purposes. According to the Court, there is “nothing in the Miranda opinion that calls for a curtailment of the warnings to be given persons under interrogation by officers based on the reason why the person is in custody.”
NOTE: The Court in Mathis did not hold that imprisonment, in and of itself, is enough to constitute Miranda custody. In addition, it was not possible to tell from either the opinion of the Supreme Court or the court below whether Mathis’ interview was routine or whether there were special features that may have created an especially
391 U.S. 1, 88 S. Ct. 1503 (1968)