In December of 2010, twelve law enforcement arrived at the door of Cooper’s home in a multi-unit residential complex in the District of Columbia to execute a search warrant. An agent knocked and announced their presence and Cooper opened the door. The agents entered and found Cooper’s six-to-seven-year-old daughter and an adult female friend of Cooper’s. After being interviewed, the friend left. About an hour into the search, two agents began interviewing Cooper in her living room. At some point in the questioning, she admitted receiving in the mail at her address one to five refund checks each week, and that her uncle paid her when she turned over the checks to him. She argues here, as she did in the district court, that the government could not introduce these statements at trial because the agents did not first give her Miranda warnings.
The district court denied Cooper’s motion. The court found that Cooper “was not coerced into answering questions” and that she was not in custody within the meaning of Miranda.
Citing Howes v. Fields, the court noted that a suspect is “in custody” if the circumstances of the questioning “present a serious danger of coercion.” To determine whether such a danger existed, courts first consider whether a reasonable person in the suspect’s position would have felt that “she was not at liberty to terminate the interrogation and leave. Relevant factors in this assessment include the location of the questioning, statements made during the interview, the presence of any physical restraints, and whether the interviewee was released once the interrogation ended. Because not all restraints on freedom of movement amount to custody for purposes of Miranda,” a finding that a person in the suspect’s shoes would not have felt free to leave does not end the inquiry. Courts must then ask the additional question whether the relevant environment presents the same inherently coercive pressures as the type of station house questioning at issue in Miranda.
In affirming the District Court’s ruling denying het motion to suppress, the DC Circuit noted that the evidence supported the conclusion that Cooper was not in custody when she admitted that she was aware of, and participated in, her uncle’s fraud. The agents questioned Cooper in her living room. When an interview takes place in a suspect’s home, that circumstance usually weighs against finding the kind of custodial situation that merits a Miranda warning. Before the interview began, the agents told Cooper that she was a subject of an investigation and described the voluntary nature of the interview. They asked her if she would agree to answer their questions. She agreed. So, Cooper’s statements were given freely and voluntarily. In addition, no weapons were brandished and no handcuffs were used. Cooper was cooperative, and the agents employed a professional and cordial tone and at no point did Cooper ask to end the questioning. Once the interview was over, the agents left without arresting her. The court held that these facts do not portray an environment presenting a “meaningful danger of coercion.”
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