The 7th Circuit Court of Appeals ruled Tuesday that a man was not under arrest when he was questioned by police and therefore did not need to be given his Miranda warnings after the man claimed he did not voluntarily agree to speak to police.
Cameron Patterson came up as a suspect during an FBI investigation of a bank robbery in Ossian. Two FBI agents came to his home dressed in casual clothes and asked if he wanted to “clear his name” regarding an investigation into a bank robbery. Patterson said he did and the agents asked if they could take him to the FBI building nearby to talk with him. Patterson agreed and after the agents double checked to make sure Patterson was coming voluntarily, they took him to the building.
There they led him into the office building which needed a card to get in but was unlocked from the inside. They went into a conference room that was also unlocked from the inside and spoke for two hours. Patterson admitted to his involvement with the robbery and asked when he would be arrested, since officers told him he would not be arrested that day.
After he was charged, Patterson filed a motion to suppress the evidence, saying officers did not give him his Miranda rights before questioning him, but the District judge denied the motion. Patterson appealed and later pleaded guilty to armed bank robbery and assault with a dangerous weapon.
In the decision written by Judge William Bauer, the court said the case hinged on whether Patterson was in custody or a reasonable person could think they were in custody, which would require a Miranda warning.
Bauer wrote there were many factors that lead to the conclusion Patterson was not under arrest. The questioning started on a driveway on a public street and then finished in a public building with the doors unlocked. There was nothing stopping Patterson from leaving at any time. Also, Patterson went with the officers voluntarily.
Patterson claimed it was a “ruse” that the officers asked him to go with them to clear his name, but Bauer disagreed.
“When told that they wanted to discuss their investigation and give Patterson an opportunity to ‘clear his name,’ a reasonable person in Patterson’s shoes would have or should have known that any ensuing discussion or interview would be about the FBI investigation,” Bauer wrote.
Patterson also argued he was not free to leave and the first encounter with the officers was confrontational because the officers were armed. However, Patterson was not restrained in any way and the officers’ guns were in their holsters the entire time.
Also, Patterson did not object to the interview at any time nor try to stop it. He also left at the end of the interview and got a ride home from the officers.
The case is United States of America v. Cameron Patterson, 15-3022.