Custody and Miranda
A police officer conducted a traffic stop in the middle of the night. Having reason to suspect Braylon Coulter had a gun, the officer handcuffed him and asked him where it was. The officer didn’t Mirandize Coulter. Coulter answered, and the officer’s late-arriving partner found it and less than half an ounce of marijuana in Coulter’s backpack that was between the front seats of Coulter’s van. Coulter later motion to suppress his statements.
The issue in the case was whether Coulter was “in custody” as contemplated by Miranda when he told the officer where the gun was. The Court held “that a reasonable person in Coulter’s position would not have thought that he was in custody for Miranda purposes.” All of his statements were therefore admissible.
The factual background of the case demonstrates an erosion of individual rights.
Coulter was driving a van with “squeaky brakes” though a neighborhood at 2:41 a.m. when officer Nino de Guzman started following him. Guzman discovered the van “was registered to an address in a different city, that its registration was expired, and that it had no insurance.” He pulled Coulter over. (Guzman later testified that the expired registration alone gave him probable cause to pull Coulter over.)
Guzman twice asked Coulter if he had any guns after Coulter had stepped out of the van. Coulter told him no. Guzman then frisked him, asked him questions about the van, and the conducted a background check. Coulter’s driver’s license had been suspended. Coulter admitted he was on parole for aggravated robbery. Guzman again asked about a gun and Coulter insisted he didn’t have one. Guzman asked if there was “anything illegal” in the van. He said he didn’t care if Coulter had a small amount of marijuana. Coulter admitted that he smoked marijuana in the van the week before and that morning. This gave Guzman probable cause to search.
Guzman testified he smelled marijuana emitting from the van. Coulter told him he “wanted to be real with [him}” before volunteering that he “did not need any more ‘strikes’ and indicated . . . that he had a gun in the van.” Sometime during the back and forth, Coulton insisted that he “had people trying to kill him . . . and did not want to be caught out there with nothing.” Guzman said he was “just going to detain him” so that he did not “run up and grab the gun.” Coulter offered to walk further away.
Guzman told Coulter to turn and face his police car and cuffed him “for officer safety.” He reiterated that Coulter was “just detained. That’s it.” He asked if Coulter understood what detention meant, but he didn’t respond. Guzman told him three times Coulter was “just detained,” but also told him not to pull away because he didn’t want to tase him and “do a bunch of paperwork.” Guzman then asked where the suspected gun was. Coulter then explicitly admitted one was in his backpack. While Coulter remained handcuffed on the street, a fellow officer arrived, searched the van, and found the gun.
Coulter later moved to suppress “all statements [he made] in response to the officer’s questioning once he was in handcuffs. He contended he was in custody once handcuffed and that Guzman did not deliver the requisite Miranda warnings. The district court granted the motion, and the Government appealed. The Government contended that a reasonable person in Coulter’s position would not have thought that the restraint on his freedom was functionally equivalent to a formal arrest that that the environment in which he was questioned did not necessitate Miranda warnings.
The court observed Miranda held custodial interrogations that necessitate Miranda warnings consist of “questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.” Restraint on freedom of movement usually resembles formal arrest when “in light of the objective circumstances of the interrogation, . . . a reasonable person [would] have felt he or she was not at liberty to terminate the interrogation and leave.”
The Fifth Circuit said that the freedom-of-movement analysis wasn’t enough. A Miranda analysis also includes an environmental analysis. In short, the court said the because Guzman did not question Coulter “in an environment resembling the station house questioning at issue in Miranda,” Coulter’s statements were admissible. The court went on, addressing five different factors, justifying its decision. In sum, Coulter could not have entertained a reasonable belief that he was in custody while he was handcuffed and threatened with tasing.
Judge Jones penned a concurring opinion, admitting the panel was “deeply divided on the application of the ‘custody’ test.”
Chief Judge Richman issued a strong dissent, concluding the restrictions placed on Coulter during the traffic stop “were of the degree associated with a formal arrest.”