United States v. Teresa Mechell Griffin
1993 U.S. App. LEXIS 27756, 7 F.3d 1512, 1993 WL 429777 (1993)
Rule of Law:
Law enforcement officers must provide Miranda warnings prior to interrogation when, under the totality of the circumstances, a reasonable person in the suspect's position would feel that their freedom of action has been curtailed to a degree associated with formal arrest.
Facts:
- Police officers at the Oklahoma City airport observed Griffin and a companion fitting a 'drug courier profile' because they purchased one-way tickets to Houston with cash just prior to departure.
- Airport security discovered .357 magnum bullets in Griffin's purse, though she was initially allowed to board the plane.
- An officer removed Griffin from the plane, and after she denied checking luggage, a search revealed baggage claim receipts and luggage containing approximately $38,500 in cash.
- A second officer, a drug detective, arrived and asked Griffin to accompany him to a private police office measuring approximately 8 by 10 feet.
- Inside the office, the detective sat behind a desk while Griffin sat next to it, with the detective positioned between Griffin and the open door.
- The detective interrogated Griffin regarding the source of the money and her employment status without reading her Miranda rights or telling her she was free to leave.
- During this questioning, Griffin confessed that the money was narcotics-related and admitted to having cocaine in her car parked off-site.
- Based on these statements, police searched her car, found cocaine, and subsequently placed her under formal arrest.
Procedural Posture:
- The government charged Griffin with multiple drug-related counts, including conspiracy to distribute cocaine.
- Griffin filed a motion to suppress the evidence obtained from her confession and the subsequent search of her car.
- The United States District Court denied the motion to suppress, finding the defendant's testimony incredible.
- Griffin was convicted on the drug charges and sentenced to life imprisonment.
- Griffin appealed the conviction and the denial of the suppression motion to the United States Court of Appeals for the Tenth Circuit.
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Issue:
Is a suspect considered to be in 'custody' for Miranda purposes when police separate her from a companion, take her to a small, private office, position themselves between her and the exit, and subject her to accusatory questioning without advising her that she is free to leave?
Opinions:
Majority - Judge Brorby
Yes. A suspect is in custody for Miranda purposes when the police create a coercive environment where a reasonable person would not feel free to terminate the interview and leave. The Court reversed the lower court's decision, determining that while the initial airport stop was a non-custodial encounter, the situation escalated into custody during the second interview. The Court reasoned that Griffin was separated from her companion and isolated in a small, police-controlled area. Crucially, the officer sat between her and the exit, did not inform her she could refuse to answer, and engaged in prolonged, accusatory questioning. Under these specific circumstances, a reasonable person would believe they had no choice but to submit to the interrogation. Because she was in custody and not read her rights, the confession and subsequent evidence derived from it must be suppressed.
Analysis:
This decision reinforces the protective scope of Miranda v. Arizona by clarifying the boundary between a voluntary police encounter (or Terry stop) and custodial interrogation. The court emphasizes that 'custody' is determined by how a reasonable person would perceive the situation, not by the officer's subjective intent or the lack of a formal 'you are under arrest' declaration. By identifying specific environmental factors—such as room size, officer positioning, and the lack of an advisement that the suspect is free to go—the Tenth Circuit places a burden on law enforcement to explicitly clarify a suspect's freedom if they wish to avoid triggering Miranda requirements during station-house style interviews. This ruling prevents police from circumventing constitutional rights by moving suspects to private rooms and conducting 'voluntary' interrogations that are coercive in reality.
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