United States v. Craighead
2008 WL 3863709, 539 F.3d 1073, 2008 U.S. App. LEXIS 17829 (2008)
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Rule of Law:
An interrogation of a suspect in their own home becomes custodial, thus requiring Miranda warnings, when the totality of the circumstances creates a 'police-dominated atmosphere' such that a reasonable person would not feel free to terminate the interrogation and leave.
Facts:
- FBI Special Agent Robin Andrews traced an IP address sharing files appearing to be child pornography to the residence of Ernest D. Craighead, an Air Force technician living on a military base.
- Eight armed law enforcement officers from three different agencies (FBI, Pima County Sheriff, and Air Force OSI) executed a search warrant at Craighead's home at approximately 8:40 A.M.
- Some officers wore raid vests, and some unholstered their firearms in Craighead's presence during the search.
- SA Andrews and Detective Jeff Englander told Craighead he was not under arrest, would not be arrested that day, and was free to leave.
- The officers then directed Craighead to a cluttered back storage room for a 'private conversation' and shut the door.
- During the 20-30 minute interview, SA Andrews squatted to take notes while Detective Englander, armed and wearing a raid vest, stood silently leaning against the wall near the door, which was the only exit.
- Sergeant Mike Ramsey, Craighead's superior officer who was present to provide 'emotional support,' was not permitted to enter the storage room during the interview.
- Without being read his Miranda rights, Craighead admitted to downloading, storing, and saving child pornography.
Procedural Posture:
- Ernest D. Craighead was indicted in the U.S. District Court for transportation, shipping, and possession of child pornography.
- Craighead filed a motion to suppress his incriminating statements, arguing they were obtained in violation of his Miranda rights.
- The district court held an evidentiary hearing and denied the motion, finding that the interrogation in Craighead's home was not custodial.
- Craighead entered a conditional guilty plea, preserving his right to appeal the district court's denial of his suppression motion.
- Craighead (appellant) appealed the district court's ruling to the U.S. Court of Appeals for the Ninth Circuit.
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Issue:
Does an interrogation of a suspect in his own home become custodial, requiring Miranda warnings, when numerous armed law enforcement officers execute a search warrant, isolate the suspect in a closed room, and position an officer by the only exit, despite telling the suspect he is free to leave?
Opinions:
Majority - Bybee, Circuit Judge
Yes, the interrogation was custodial. An in-home interrogation becomes custodial when the circumstances transform the home into a 'police-dominated atmosphere' where a reasonable person would not feel at liberty to terminate the interview. The court applied a four-factor test, considering: 1) the number of armed officers, 2) whether the suspect was restrained, 3) whether the suspect was isolated, and 4) whether the suspect was told he was free to leave. Here, the presence of eight armed officers from three agencies created an overwhelming police presence. Craighead was effectively restrained when escorted to a back room where a detective guarded the only exit. He was isolated from his superior officer who was there for support. Although SA Andrews told Craighead he was free to leave, a reasonable person in his position—surrounded by officers, with his home being searched, and confined to a back room with a guarded exit—would not have felt genuinely free to terminate the interrogation.
Analysis:
This decision establishes a key precedent in the Ninth Circuit for determining when an in-home interrogation crosses the threshold into a custodial situation requiring Miranda warnings. It clarifies that the familiar setting of a home does not automatically make an interview non-custodial and that a verbal advisement that a suspect is 'free to leave' can be overcome by coercive circumstances. The court's adoption of the 'police-dominated atmosphere' test, supported by a clear four-factor framework, provides lower courts with a structured analysis for future cases, emphasizing that the objective reality of the situation outweighs formalistic statements made by officers.
