In this case the defendant claims that statements he made during questioning should be suppressed because he was not provided with Miranda warnings prior to questioning. In order for Miranda warnings to be triggered, there must be a custodial interrogation by a person who the subject knows is a LEO. The defendant argued that since he was an inmate, he was in custody for Miranda purposes and therefore a warning should have been provided.
The Fifth Circuit disagreed and held that the defendant was not in custody for Miranda purposes. Citing Howes v. Fields. 565 U.S. 499 (2012), the court noted that the defendant was not told he was free to leave (as was the defendant in Howes) but the defendant was told that his “statement had to be voluntary” and that “the interview would terminate if he chose not to speak to the officer.” Given these facts, under the requisite objective test a reasonable person would have felt free to terminate the interview and leave. Accordingly, he was not in custody for Miranda purposes.
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