United States v. Jimmy Brown, Also Known as Marlus Andrew Singleton
101 F.3d 1272, 1996 U.S. App. LEXIS 31046, 1996 WL 691629 (1996)
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Rule of Law:
Asking a lawfully arrested suspect for routine biographical information, such as their name, does not constitute interrogation for Miranda purposes and does not require Miranda warnings, unless the officer should reasonably be aware the question is designed to elicit an incriminating response relevant to the substantive offense.
Facts:
- A police informant notified Officer Donald Sebesta of an impending drug transaction involving an individual named 'Dre' (Deandre Norris) at an Exel Inn.
- The informant stated that a female courier would arrive from Los Angeles with crack cocaine and that Norris would pick her up in a specific car.
- Police surveillance observed Norris and Jimmy Brown leave the Exel Inn in the described car, with Brown driving.
- Brown and Norris drove a circuitous route to the Minneapolis-St. Paul International Airport and picked up a female passenger, Sherdaria Conklin, who had arrived on a flight from Los Angeles.
- They returned to the Exel Inn via another indirect route, where Norris and Conklin took two bags from the car into a hotel room.
- Police later found cocaine in one of the bags in the hotel room.
- After Norris and Conklin entered the hotel, Brown drove away alone in the car, at which point officers pursued, stopped, and arrested him.
Procedural Posture:
- Jimmy Brown was charged in the United States District Court for the District of Minnesota with aiding and abetting possession with intent to distribute cocaine base and conspiracy.
- Brown filed pretrial motions to suppress the false name he gave to police and evidence seized from his car.
- A United States Magistrate Judge recommended that the motions be denied.
- The district court adopted the magistrate judge's report and recommendation and denied Brown's suppression motions.
- After a jury trial, Brown was convicted on both counts.
- Brown appealed the district court's denial of his motions to suppress to the United States Court of Appeals for the Eighth Circuit.
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Issue:
Does questioning a lawfully arrested suspect about their name, without prior Miranda warnings, constitute a custodial interrogation that violates the suspect's Fifth Amendment rights?
Opinions:
Majority - Hansen, J.
No, questioning a lawfully arrested suspect about their name does not constitute a custodial interrogation that violates the suspect's Fifth Amendment rights. The court held that a request for routine biographical data is exempted from Miranda's coverage under the 'routine booking question' exception. This exception applies unless the officer should reasonably know that the question is directly relevant to the substantive offense and designed to elicit an incriminating admission. In this case, Brown was arrested based on probable cause for his participation in a drug crime, and his name was incidental to that offense, not directly relevant. The question was a standard part of the booking process, not an investigative tool. Additionally, the court affirmed the denial of the motion to suppress evidence from Brown's vehicle, holding that the search was a valid search incident to a lawful arrest.
Analysis:
This decision reinforces and clarifies the scope of the 'routine booking question' exception to the Miranda rule. It establishes that the exception applies even when police do not know the suspect's identity, focusing the inquiry on the nature of the question rather than the suspect's anonymity. The ruling provides law enforcement with clear authority to ask for basic identifying information post-arrest without triggering Miranda, thereby streamlining the booking process. The key distinction highlighted is whether the question is for administrative purposes or is a disguised attempt at substantive interrogation about the offense itself.
