Orozco was the suspect in a shooting at a restaurant that left one man dead. At approximately 4:00 a.m., four officers went to Orozco’s boardinghouse where they were admitted by a woman who told the officers that Orozco was asleep in the bedroom. The officers entered Orozco’s bedroom and questioned him. Orozco told the officers he was at the restaurant earlier that night, and he admitted owning a pistol. Orozco eventually told the officers where they could locate the pistol. The officers recovered the pistol and ballistics tests indicated it was the pistol that had fired the fatal shot. At no time, did the officers advise Orozco of his Miranda rights. At trial, one of the officers testified about Orozco’s statements concerning the pistol and about Orozco’s admission that he was at the scene of the shooting.
Whether Orozco’s admissions were obtained in violation of Miranda.
Yes. The use of Orozco’s admissions obtained in the absence of the required warnings was a violation of the Self-Incrimination Clause of the Fifth Amendment as construed in Miranda.
The State argued that since Orozco was interrogated on his own bed, in familiar surroundings, the officers were not required to advise him of his Miranda rights before they interrogated him. While Miranda involved a situation where a suspect was interrogated at the police station, in its opinion the Supreme Court emphasized the absolute necessity for officers interrogating people “in custody” to first advise them of the warnings provided in Miranda. The Miranda opinion held that the warnings were required when the person being interrogated was “in custody at the station or otherwise deprived of his freedom of action in any significant way.” According to the testimony of one of the officers, from the moment he gave his name, Orozco was not free to go where he pleased but was “under arrest.” For this reason, Orozco’s admissions, without the benefit of Miranda warnings, were obtained in violation of the Fifth Amendment privilege against compelled self-incrimination.
394 U.S. 324, 89 S. Ct. 1095 (1969)