In a pair of last year’s blog posts, we talked about Miranda warnings, and how they’re only required after you’ve been taken into “custody,” which is not a simple concept.
Now, a new case out of Maine showcases just how complex the idea of custody can become.
In April, 2016, police had found evidence that Luis Medina was committing identity fraud by using a different name to get a driver’s license. When they saw his car on the road, police conducted a traffic stop.
The police officer conducting the stop immediately asked Medina to turn off the engine and get out of the car. Noting that Medina was “in very good physical shape,” the officer put him in handcuffs. Because the officers didn’t think that this was “custody,” they didn’t tell Medina of his Miranda rights, including the right to be silent.
The police then questioned Medina through an interpreter. What Medina said was used as evidence that he was committing identity fraud. Medina was then fingerprinted before the police, finally, gave him his Miranda warning.
Medina was charged with identity fraud, and his criminal defense attorney argued that, because he was in custody but hadn’t been Mirandized, what Medina said couldn’t be used in trial. However, in United States v. Medina, the federal court in Maine disagreed.
As soon as you get put in custody, police have to tell you of your Miranda rights before they can interrogate you. If they don’t tell you of your rights, then whatever you say can be excluded from your trial and cannot be used against you.
However, the court in Medina decided that, even though Medina was put in handcuffs, he was not in “custody” yet. According to the court, handcuffs are not, in and of themselves, enough to create “custody.” This is despite the fact that they prevent a suspect from moving freely and are a tell-tale sign of police using their authority over someone – two signature aspects of an arrest.
Instead, the court looked to the “totality of the circumstances” surrounding Medina’s detention. They ruled that the handcuffs only shifted the burden of proof back to law enforcement to show that Medina was not in custody. Police had to show a “specific fact or circumstance” that made the handcuffs necessary.
That “specific fact or circumstance” was Medina’s “very good physical shape” which, coupled with the officer’s belief that Medina would want to conceal his true identity, made him a flight risk.
This case showcases how complex the concept of “custody” can be. Clear signs that you are under arrest – like being handcuffed – are apparently not enough for courts to decide that you’re in legal custody and need to be told of your Miranda rights.
Ambiguities like these just make it all the more important to have a solid criminal defense attorney at your side if you’ve been charged with a crime in the state of Maine. Call the law office of William T. Bly at (207) 571-8146 or contact him online.
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