Oregon v. Mathiason Case Brief

Why is the case important?

An individual confessed to the police at a patrol office. after being told he was not under arrest.

Facts of the case

“An Oregon state police officer suspected Carl Mathiason of burglary and asked him to come to the police station for questioning. Mathiason came freely, spoke with the officer, and was not arrested at the time. He was arrested later and a trial court used evidence obtained during the questioning to convict him. Mathiason moved to suppress the evidence since he was not read his Miranda rights before the questioning. The court admitted the evidence since Mathiason was not in custody during the questioning. The Oregon Court of Appeals affirmed. The Supreme Court of Oregon reversed since it found that Matianson was in a “”coercive environment”” when questioned and therefore deserved to hear his Miranda rights.”

Question

Whether the Respondent’s Miranda rights were violated?

Answer

No. In the present case there is no indication that the questioning took place in a context where respondent’s freedom to depart was restricted in any way. He came voluntarily to the police station, where he was immediately informed that he was not under arrest. At the close of a 1/2-hour interview respondent did in fact leave the police station without hindrance. It is clear from these facts that Mathiason was not in custody ‘or otherwise deprived of his freedom of action in any significant way.’
Such a noncustodial situation is not converted to one in which Miranda applies simply because a reviewing court concludes that, even in the absence of any formal arrest or restraint on freedom of movement, the questioning took place in a ‘coercive environment.’ Any interview of one suspected of a crime by a police officer will have coercive aspects to it, simply by virtue of the fact that the police officer is part of a law enforcement system which may ultimately cause the suspect to be charged with a crime. But police officers are not required to administer Miranda warnings to everyone whom they question. Nor is the requirement of warnings to be imposed simply because the questioning takes place in the station house, or because the questioned person is one whom the police suspect. Miranda warnings are required only where there has been such a restriction on a person’s freedom as to render him ‘in custody.’ It was that sort of coercive environment to which Miranda by its terms was
made applicable, and to which it is limited.

Conclusion

The Supreme Court of the United States reversed the state supreme court judgment that reversed Mathiason’s conviction and remanded the case for further proceedings. The Court found that because Mathiason had come voluntarily to the station, he was seated at a desk, he was told that he was free to go, and because he did in fact leave at the conclusion of a 30 minute interview, no Miranda violation occurred. The Court found that no custody was proven, thus Miranda was not applicable. The Court stated that such noncustodial situations were not converted into Miranda situations just because the questioning took place in a coercive environment. The Court further stated that police officers were not required to administer Miranda warnings to every person that they questioned, nor to everyone who came to the station house for an interview. Miranda only applied in those situations where the person was in custody.

  • Case Brief: 1977
  • Petitioner: Oregon
  • Respondent: Carl Mathiason
  • Decided by: Burger Court

Citation: 429 US 492 (1977)
Decided: Jan 25, 1977