Monday, November 4, 2013

Oregon v. Mathiason case brief

Oregon v. Mathiason case brief summary
429 U.S. 492 (1977)

A state petitioned for writ of certiorari to review the judgment by the Supreme Court of Oregon reversing defendant's conviction. The state claimed that the Supreme Court of Oregon erred when it reversed defendant's conviction for first-degree burglary because he was not in custody at the time he gave his confession, and therefore Miranda would not have applied.

The state complained that the state supreme court interpreted Miranda too broadly and that defendant was not entitled to Miranda warnings under the circumstances. The state supreme court said that because defendant was in a police station behind closed doors, and told that his fingerprints were found at the scene, he was in a coercive environment, and Miranda applied.

  • The Court disagreed. The Court found that because defendant 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 go 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 said that such noncustodial situations were not converted into Miranda situations just because the questioning took place in a coercive environment. 
  • The court also said 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.


The Court granted the petition for writ of certiorari, reversed the state supreme court judgment that reversed defendant's conviction, and remanded the case for further proceedings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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