United States v. Reid
211 F. Supp. 2d 366, 2002 U.S. Dist. LEXIS 12972, 2002 WL 1581185 (2002)
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Rule of Law:
A suspect's unequivocal invocation of the right to remain silent does not create a permanent bar to all future questioning; subsequent statements are admissible if law enforcement "scrupulously honored" the suspect's right to cut off questioning by, among other factors, ceasing the initial interrogation, waiting a significant period of time, and re-administering Miranda warnings before resuming.
Facts:
- On December 22, 2001, after allegedly attempting to detonate an explosive device on an airplane, Richard C. Reid was taken into custody by Massachusetts State Police upon landing in Boston.
- After being read his Miranda rights, Reid was placed in a police cruiser with State Trooper Louis Santiago for transport.
- In the cruiser, Trooper Santiago asked Reid several questions, including 'What happened on the plane?'.
- Following a brief exchange about the media's absence, Reid became indignant and stated, 'I have nothing else to say.'
- After Reid's statement, the conversation between him and Trooper Santiago stopped.
- Approximately four hours later, at a State Police barracks, federal agents re-administered Miranda warnings to Reid.
- Reid then agreed to speak with the federal agents and proceeded to answer some questions over the next two and a half hours, while declining to answer others.
- The following day, agents questioned Reid again after he was reminded of his rights and signed a Miranda consent form.
Procedural Posture:
- Richard C. Reid was taken into federal custody and charged with crimes related to an attempted bombing of an aircraft.
- Reid filed a Motion to Suppress Statements in the United States District Court for the District of Massachusetts, arguing that statements made on December 22 and 23, 2001, were obtained in violation of his Miranda rights.
- The District Court held a five-day suppression hearing to consider the motion.
- The court previously denied part of the motion, finding that sedatives administered to Reid had not rendered his statements involuntary.
- The court now considers the separate argument of whether Reid's statement 'I have nothing else to say' constituted an invocation of his right to silence requiring suppression of subsequent statements.
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Issue:
Does law enforcement's resumption of questioning approximately four hours after a suspect in custody states 'I have nothing else to say' violate the suspect's Fifth Amendment right to remain silent, thereby requiring suppression of subsequent statements?
Opinions:
Majority - Young, Chief Judge
No. Although the suspect's statement was an unequivocal invocation of his right to remain silent, law enforcement scrupulously honored that right, making the subsequent statements admissible. The court first determined that Reid's statement, 'I have nothing else to say,' was a clear and unambiguous invocation of his right to silence, satisfying even the demanding standard from Davis v. United States. The court found the words themselves, viewed in context, left no doubt that Reid wished to cease questioning. However, citing Michigan v. Mosley, the court evaluated whether police scrupulously honored Reid's invocation. The court found they did by: (1) immediately ceasing questioning after his statement; (2) waiting a significant period of time (almost four hours); (3) re-administering Miranda warnings twice before the new interrogation began; and (4) ensuring the subsequent interrogation was not coercive. While the second interrogation concerned the same crime as the first, these other factors overwhelmingly demonstrated that Reid’s right to cut off questioning was respected.
Analysis:
This case clarifies the two-step analysis required for post-invocation statements under Miranda. It affirms that common phrases like 'I have nothing else to say' can constitute an unambiguous invocation of the right to silence. However, the decision heavily emphasizes the importance of the Michigan v. Mosley 'scrupulously honored' factors, demonstrating that a clear invocation does not create a per se bar to all future questioning. This provides a practical roadmap for law enforcement on how to properly re-engage a suspect after they have invoked their right to silence, focusing on the passage of time, fresh warnings, and a non-coercive environment.
