United States v. Brown

FARRELL, Associate Judge:

The requirement that the police advise a suspect in accordance with Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966), is triggered by custodial interrogation. See id. at 444, 86 S.Ct. 1602; Rhode Island v. Innis, 446 U.S. 291, 300, 100 S.Ct. 1682, 64 L.Ed.2d 297 (1980). In this case there is no dispute that defendant Brown was in custody at the relevant time; the issue rather is whether he was “interrogated” before the police advised him of his Miranda rights. The trial judge ruled that he was, and therefore suppressed incriminating statements…