Thompson v. Keohane
516 U.S. 99 (1995)
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Rule of Law:
A state court's determination of whether a suspect is 'in custody' for Miranda purposes is a mixed question of law and fact, not a finding of fact. Therefore, it is not entitled to a statutory presumption of correctness and is subject to independent (de novo) review in a federal habeas corpus proceeding.
Facts:
- On September 10, 1986, the body of Dixie Thompson was discovered in a gravel pit lake in Alaska.
- Her former husband, Carl Thompson, contacted Alaska state troopers after a press release to report that she had been missing.
- On September 15, a trooper asked Thompson to come to the headquarters, ostensibly to identify personal items, but primarily to question him about the murder.
- Thompson drove himself to the headquarters and, after identifying the items, was questioned by two unarmed troopers for two hours in a small interview room.
- The troopers did not give Thompson Miranda warnings, but they repeatedly told him he was free to leave.
- During the interrogation, the troopers told Thompson they knew he had killed his ex-wife and informed him that search warrants were being executed on his home and truck.
- Thompson eventually confessed to the murder.
- After confessing, troopers allowed Thompson to leave and gave him a ride home because they had impounded his truck; he was formally arrested two hours later.
Procedural Posture:
- The State of Alaska charged Thompson with first-degree murder.
- In the Alaska state trial court, Thompson moved to suppress his confession, arguing it was obtained in violation of his Miranda rights.
- The trial court denied the motion, ruling that Thompson was not 'in custody' during the interrogation.
- A jury subsequently convicted Thompson of first-degree murder after his confession was admitted into evidence.
- Thompson, as appellant, appealed to the Court of Appeals of Alaska, which affirmed the conviction, agreeing he was not in custody.
- The Alaska Supreme Court denied discretionary review.
- Thompson filed a petition for a writ of habeas corpus in the U.S. District Court for the District of Alaska.
- The District Court denied the petition, applying the § 2254(d) presumption of correctness to the state court's 'in custody' finding.
- Thompson, as appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit, which affirmed the District Court's decision.
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Issue:
Is a state court's determination that a suspect was not 'in custody' for Miranda purposes a finding of fact entitled to a presumption of correctness under 28 U.S.C. § 2254(d) in a federal habeas corpus proceeding?
Opinions:
Majority - Justice Ginsburg
No, a state court's 'in custody' determination is not a finding of fact entitled to a presumption of correctness; it is a mixed question of law and fact subject to independent review. The 'in custody' inquiry involves two steps: 1) determining the historical facts of the interrogation, which are presumed correct, and 2) applying the objective legal standard to those facts to determine if a reasonable person would have felt free to leave. This second step is the ultimate legal question, not a 'basic, primary, or historical fact.' Unlike credibility-dependent issues such as juror bias, a trial court has no special advantage in making this determination, and independent federal review is necessary to unify precedent and ensure the uniform application of federal constitutional law under Miranda.
Dissenting - Justice Thomas
Yes, a state court's 'in custody' determination should be treated as a finding of fact entitled to a presumption of correctness. The question is a fact-laden inquiry that requires assessing a complex set of case-specific factors, including credibility and demeanor, which are not easily discernible from a cold record. The state trial judge is in the best position to evaluate the totality of the circumstances and understand how a reasonable person in the suspect's position would have perceived the situation. Federal habeas courts, reviewing the case years later, are in an inferior position, and treating the issue as a mixed question of law undermines the competence and finality of state court judgments.
Analysis:
This decision significantly clarifies the standard of review for a critical component of Miranda rights in federal habeas proceedings. By classifying the 'in custody' determination as a mixed question of law and fact, the Court ensures federal courts can independently scrutinize state court applications of this federal constitutional standard. This holding prevents state courts from narrowly interpreting 'custody' in a way that would be insulated by the highly deferential review under § 2254(d). The ruling strengthens federal oversight of state criminal convictions and aligns the 'in custody' question with other ultimate constitutional issues, such as the voluntariness of a confession, that receive independent federal review.
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