United States v. Lnu, No. 10-419 (2d Cir. 2011)
Annotate this CaseDefendant appealed her conviction of immigration offenses after the district court denied her motion to suppress testimony from the officer who questioned her without Miranda warnings on her arrival at John F. Kennedy International Airport. At issue was whether the district court correctly ruled that the officer's questioning failed to rise to the level of a "custodial interrogation" under Miranda and thus, whether that court properly admitted into evidence defendant's statements to the officer. The court held that, in light of the totality of the circumstances, a reasonable person in defendant's position would not have considered what occurred to be the equivalent of a formal arrest. Therefore, it followed that defendant was not in "custody" and that, for this reason alone, Miranda warnings were not required. Accordingly, the district court correctly denied the motion to suppress the officer's testimony.
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