United States v. Leonard David Griffin
1990 WL 212298, 922 F.2d 1343, 1990 U.S. App. LEXIS 22396 (1990)
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Rule of Law:
An interrogation is custodial for Miranda purposes if, under the totality of the circumstances, a reasonable person in the suspect's position would believe their freedom of action has been curtailed to a degree associated with a formal arrest. Factors indicating custody include police domination of the setting, restriction of the suspect's movement, and failure to inform the suspect they are free to leave, even when the interrogation occurs in the suspect's own home.
Facts:
- On February 25, 1989, two men, one black and one white, robbed the Twin Cities Federal Savings and Loan Association (TCF) using a shotgun.
- The FBI's investigation led them to suspect Leonard David Griffin, a black male, after tracing a cab ride from near the scene to a hotel room and then connecting associates from there.
- On March 1, 1989, two FBI agents went to Griffin's home to interview him, arriving before he did and waiting inside with his stepfather's permission.
- When Griffin entered his home, the agents identified themselves, and Griffin spontaneously stated, 'The gun wasn’t loaded.'
- The agents then separated Griffin from his parents, taking him into the dining room for a private, two-hour interrogation.
- During the interview, the agents required that one of them escort Griffin whenever he left the room to get cigarettes, telling him he was to stay in their view at all times.
- The agents did not inform Griffin that he was not under arrest or that he was free to leave or to refuse to answer questions.
- Throughout the questioning, Griffin appeared nervous and fearful, and he ultimately made statements implicating himself in the robbery.
Procedural Posture:
- Leonard David Griffin was indicted for armed bank robbery and use of a firearm during a crime of violence.
- Griffin filed a pre-trial motion in the U.S. District Court for the District of Minnesota to suppress incriminating statements he made to FBI agents.
- The district court referred the motion to a U.S. Magistrate, who recommended denying the motion.
- The district court adopted the magistrate's findings and denied the motion to suppress, concluding Griffin was not in custody.
- Griffin entered a conditional plea of guilty, reserving his right to appeal the court's denial of his suppression motion.
- Griffin (appellant) appealed the district court's final judgment to the United States Court of Appeals for the Eighth Circuit.
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Issue:
Does a police interrogation become 'custodial,' requiring Miranda warnings, when law enforcement officers question a suspect in his own home, restrict his movement, isolate him from family, and do not inform him that he is free to leave or terminate the interview?
Opinions:
Majority - Battey, District Judge
Yes. An interrogation becomes custodial under these circumstances because a suspect's freedom of action is curtailed to a degree associated with formal arrest. The determination of custody requires an examination of the totality of the circumstances from the perspective of a reasonable person in the suspect's position. Here, none of the mitigating factors indicating a non-custodial setting were present: Griffin was not told he was free to leave, his freedom of movement was restrained (he was escorted to get cigarettes and told to remain in sight), and the contact was initiated by the police, not him. Conversely, several coercive factors were present: the atmosphere was police-dominated (agents took control, isolated him from his parents), and he was arrested immediately following the interrogation. These circumstances, combined, created a custodial environment requiring Miranda warnings, regardless of the fact the interrogation took place in Griffin's home and no overt strong-arm tactics were used.
Analysis:
This case clarifies the application of the 'custody' test for Miranda purposes, particularly in the context of in-home interrogations. It emphasizes that the location of the interview is not dispositive; rather, the key is the degree of restraint and psychological coercion imposed by law enforcement. The court's detailed six-factor framework provides lower courts and law enforcement with a clearer analytical structure for determining when an encounter becomes custodial. The decision signals that courts will look critically at police actions that create a coercive, police-dominated atmosphere, even in a familiar setting, to protect a suspect's Fifth Amendment rights.
