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Wednesday, June 15, 2016

Ind. Decisions - 7th Circuit posts Indiana case decided Tuesday

In USA v. Cameron Patterson (ND Ind., Springmann), a 16-page opinion, Judge Bauer wrtes:

Miranda warnings have taken a foothold in American culture largely via crime drama television and film. Defendant-appellant, Cameron E. Patterson, argues Federal Bureau of Investigation agents violated his Fifth Amendment right against self-incrimination when they failed to give him Miranda warnings prior to interviewing him. The sole issue is whether Patterson was “in custody” when he made his incriminating statements, thereby implicating the Fifth Amendment and necessitating Miranda warnings. We find Patterson was not in custody for purposes of Miranda, and therefore affirm the district court’s order denying the motion to suppress his statements. * * *

Considering the totality of the circumstances, from the beginning of the encounter in the driveway to the end of the interrogation when Patterson walked out of the FBI office, Patterson was not in custody for purposes of Miranda. AFFIRM

Posted by Marcia Oddi on June 15, 2016 10:35 AM
Posted to Ind. (7th Cir.) Decisions