US v. Ervin Leggette, No. 21-4175 (4th Cir. 2023)
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Defendant and another person were trespassing in a public park after it closed. When officers saw their car, they investigated the trespass. The officers found a gun abandoned in a nearby trash can, so they frisked Defendant and questioned him about the gun. After first denying the gun was his, Defendant admitted he was a felon and that he owned the gun. The officers arrested Defendant, who was then federally indicted for being a felon in possession of a firearm. He sought to suppress his incriminatory statements, arguing that his statements in the park were inadmissible because he was “in custody” under Miranda, and so the officers needed to read him his Miranda rights before questioning him about the gun. The district court disagreed, and Defendant pleaded guilty.
The Fourth Circuit affirmed. The court explained that Miranda warnings are not required every time an individual has their freedom of movement restrained by a police officer. Nor are they necessarily required every time “questioning imposes some sort of pressure on suspects to confess to their crimes.” Instead, they are required only when a suspect’s freedom of movement is restrained to the point where they do not feel free to terminate the encounter, and the circumstances reveal “the same inherently coercive pressures as the type of station house questioning at issue in Miranda.” The court found that, in this case, no such pressures existed.
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