United States of America v. Glenn W. Hall

Rule of Law:

For Miranda purposes, interrogation is 'custodial' when a person has been taken into custody or otherwise deprived of freedom in any significant way. In the absence of a formal arrest, custody is determined by an objective test of whether the authorities, by their words or actions, indicated that the person being questioned was not free to leave.

Facts:

• On the morning of December 12, 1968, a man wearing a stocking mask and carrying a rifle robbed The Merchants National Bank in Cicero, NY.
• The robber forced an employee, Mrs. Richer, to put cash into a bag, took her car keys, and fled in her car, which was later found in a nearby bowling alley parking lot.
• A witness, Barbara Costick, who was in the bowling alley parking lot before the robbery, observed a suspicious man in a red car hiding his face and wrote down the license plate number.
• The license plate was traced to a Chevrolet assigned by an insurance company to its employee, defendant Hall.
• At 4:22 P.M. that day, three FBI agents went to Hall's apartment, and he voluntarily allowed them inside to speak with them.
• The agents told Hall a car matching his was seen near a bank robbery and, for approximately seventeen minutes, questioned him about his whereabouts that morning.
• During this initial questioning, Hall falsely stated that his car had been parked at his home all morning and he had risen at 9:00 A.M.

Procedural Posture:

• Hall was indicted in federal trial court for bank robbery.
• Prior to trial, Hall filed a motion to suppress the false exculpatory statement he made during the initial seventeen minutes of questioning, arguing it was obtained in violation of his Miranda rights.
• The trial court denied the motion to suppress the statement.
• Following a trial, a jury convicted Hall of bank robbery.
• Hall, as appellant, appealed his conviction to the U.S. Court of Appeals for the Second Circuit, challenging the trial court's denial of his suppression motion.