Beckwith v. United States

CourtUnited States Supreme Court
Citation425 U.S. 341,48 L.Ed.2d 1,96 S.Ct. 1612
Docket NumberNo. 74-1243,74-1243
PartiesAlvin A. BECKWITH, Jr., Petitioner, v. UNITED STATES
Decision Date21 April 1976

48 L.Ed.2d 1
96 S.Ct. 1612
425 U.S. 341
Alvin A. BECKWITH, Jr., Petitioner,



No. 74-1243.
Argued Dec. 1, 1975.
Decided April 21, 1976.

Statements made by petitioner taxpayer to Internal Revenue agents during the course of a noncustodial interview in a criminal tax investigation Held admissible against him in the ensuing criminal tax fraud prosecution even though he was not given warnings required by Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694. Although the "focus" of the investigation may have been on petitioner when he was interviewed, in the sense that his tax liability was under scrutiny, that is not the equivalent of "focus" for Miranda purposes, which involves "questioning initiated by law enforcement officers After a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." Id., at 444, 86 S.Ct. at 1612, 16 L.Ed.2d at 706 (emphasis supplied). Pp. 344-348.

166 U.S.App.D.C. 361, 510 F.2d 741, affirmed.

John G. Gill, Jr., Washington, D. C., for petitioner.

Scott P. Crampton, Washington, D. C., for respondent.

Mr. Chief Justice BURGER delivered the opinion of the Court.

The important issue presented in this case is whether a special agent of the Internal Revenue Service, investigating potential criminal income tax violations, must, in

Page 342

an interview with a taxpayer, not in custody, give the warnings called for by this Court's decision in Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). We granted certiorari to resolve the conflict between the holding of the Court of Appeals in this case, which is consistent with the weight of authority on the issue,1 and the position adopted by the United States Court of Appeals for the Seventh Circuit.2

The District Court conducted a thorough inquiry into the facts surrounding the interview of petitioner before ruling on his motion to suppress the statements at issue. After a considerable amount of investigation, two special agents of the Intelligence Division of the Internal Revenue Service met with petitioner in a private home where petitioner occasionally stayed. The senior agent testified that they went to see petitioner at this private residence at 8 a. m. in order to spare petitioner the possible embarrassment of being interviewed at his place of employment which opened at 10 a. m. Upon their arrival, they identified themselves to the person answering the door and asked to speak to petitioner. The agents were invited into the house and, when petitioner entered the room where they were waiting, they introduced them-

Page 343

selves and, according to the testimony of the senior agent, Beckwith then excused himself for a period in excess of five minutes, to finish dressing.3 Petitioner then sat down at the dining room table with the agents; they presented their credentials and stated they were attached to the Intelligence Division and that one of their functions was to investigate the possibility of criminal tax fraud. They then informed petitioner that they were assigned to investigate his federal income tax liability for the years 1966 through 1971. The senior agent then read to petitioner from a printed card the following:

"As a special agent, one of my functions is to investigate the possibility of criminal violations of the Internal Revenue laws, and related offenses.

"Under the Fifth Amendment to the Constitution of the United States, I cannot compel you to answer any questions or to submit any information if such answers or information might tend to incriminate you in any way. I also advise you that anything which you say and any information which you submit may be used against you in any criminal proceeding which may be undertaken. I advise you further that you may, if you wish, seek the assistance of an attorney before responding." App. 65-66.

Petitioner acknowledged that he understood his rights. The agents then interviewed him until about 11 o'clock. The agents described the conversation as "friendly" and "relaxed." The petitioner noted that the agents did not "press" him on any question he could not or chose not to answer.

Prior to the conclusion of the interview, the senior agent requested that petitioner permit the agents to

Page 344

inspect certain records. Petitioner indicated that they were at his place of employment. The agents asked if they could meet him there later. Having traveled separately from petitioner, the agents met petitioner approximately 45 minutes later and the senior agent advised the petitioner that he was not required to furnish any books or records; petitioner, however, supplied the books to the agents.

Prior to trial, petitioner moved to suppress all statements he made to the agents or evidence derived from those statements on the ground that petitioner had not been given the warnings mandated by Miranda. The District Court ruled that he was entitled to such warnings "when the court finds as a fact that there were custodial circumstances." The District Judge went on to find that "on this record . . . there is no evidence whatsoever of any such situation." The Court of Appeals affirmed the judgment of conviction. 166 U.S.App.D.C. 361, 510 F.2d 741 (1975). It noted that the reasoning of Miranda was based "in crucial part" on whether the suspect "has been taken into custody or otherwise deprived of his freedom in any significant way," Id., at 362, 510 F.2d, at 742, citing Miranda, supra, 384 U.S. at 477, 86 S.Ct. at 1629, 16 L.Ed.2d at 725; and agreed with the District Court that "Beckwith was neither arrested nor detained against his will." 166 U.S.App.D.C., at 362, 510 F.2d, at 742. We agree with the analysis of the Court of Appeals 4 and, therefore, affirm its judgment.

Petitioner contends that the "entire starting point" for the criminal prosecution brought against him was secured from his own statements and disclosures during the interview with the Internal Revenue agents from the

Page 345

Intelligence Division. He correctly points out that cases are assigned to the Intelligence Division only when there is some indication of criminal fraud and that, especially since tax offenses rarely result in pretrial custody, the taxpayer is clearly the "focus" of a criminal investigation when a matter is assigned to the Intelligence Division. Given the complexity of the tax structure and the confusion on the part of taxpayers between the civil and criminal function of the Internal Revenue Service, such a confrontation, argues petitioner, places the taxpayer under "psychological restraints" which are the functional, and, therefore, the legal, equivalent of custody. In short we agree with Chief Judge Bazelon, speaking for a unanimous Court of Appeals, that

"(t)he major thrust of Beckwith's argument is that the principle of Miranda and Mathis5 should be extended to cover interrogation in non-custodial circumstances after a police investigation has focused on the suspect." Ibid.

With the Court of Appeals, we "are not impressed with this argument in the abstract nor as applied to the particular facts of Beckwith's interrogation." Ibid. It goes far beyond the reasons for that holding and such an extension of the Miranda requirements would cut this Court's holding in that case completely loose from its own explicitly stated rationale. The narrow issue before the Court in Miranda was presented very precisely in the opening paragraph of that opinion "the admissibility of statements obtained from an individual who is subjected to Custodial police interrogation." 384 U.S., at 439, 86 S.Ct. at 1609, 16 L.Ed.2d at 704.6 (Emphasis supplied.) The Court concluded

Page 346

that compulsion is "inherent in custodial surroundings,"7 Id., at 458, 86 S.Ct. at 1619, 16 L.Ed.2d at 714, and, consequently, that special safeguards were required in the case of "incommunicado interrogation of individuals in a police-dominated atmosphere, resulting in self-incriminating statements without full warnings of constitutional rights." Id., at 445, 86 S.Ct. at 1612, 16 L.Ed.2d at 707. In subsequent decisions, the Court specifically stressed that it was the Custodial nature of the interrogation which triggered the necessity for adherence to the specific requirements of its Miranda holding. Orozco v. Texas, 394 U.S. 324, 89 S.Ct. 1095, 22 L.Ed.2d 311 (1969); Mathis v....

To continue reading

Request your trial
922 cases
  • Bucio v. Sutherland, No. 1:08-cv-00118.
    • United States
    • United States District Courts. 6th Circuit. United States District Courts. 6th Circuit. Southern District of Ohio
    • 4 Diciembre 2009
    ...deprived of his freedom of action in any significant way." Miranda, 384 U.S. at 444, 86 S.Ct. 1602. See also Beckwith v. United States, 425 U.S. 341, 346-47, 96 S.Ct. 1612, 48 L.Ed.2d 1 (1976). The test for determining whether a given person is "in custody" is an objective one. Stansbury v.......
  • Snyder v. State, S-20-0245
    • United States
    • United States State Supreme Court of Wyoming
    • 12 Octubre 2021 independent determination of the ultimate issue of voluntariness.’ " Id ., ¶ 50, 84 P.3d at 339 (quoting Beckwith v. United States , 425 U.S. 341, 348, 96 S.Ct. 1612, 1617, 48 L.Ed.2d 1 (1976) ). Sen v. State , 2013 WY 47, ¶ 15, 301 P.3d 106, 114 (Wyo. 2013). If the court concludes a def......
  • State v. Stankowski
    • United States
    • Supreme Court of Connecticut
    • 16 Noviembre 1981
    ...officials; Oregon v. Mathiason, 429 U.S. 492, 495, 97 S.Ct. 711, 714, 50 L.Ed.2d 714 (1977); Beckwith v. United States, 425 U.S. 341, 344-48, 96 S.Ct. 1612, 1615-1617, 48 L.Ed.2d 1 (1976); and the suspect must be subjected to interrogation. Rhode Island v. Innis, 446 U.S. 291, 100 S.Ct. 168......
  • United States v. Patterson, CRIMINAL DOCKET No. 19-27
    • United States
    • United States District Courts. 5th Circuit. United States District Court (Eastern District of Louisiana)
    • 11 Junio 2019
    ...was not in custody and the agents were not required to advise Patterson of her Miranda rights on May 28. See Beckwith v. United States , 425 U.S. 341, 342, 96 S.Ct. 1612, 48 L.Ed.2d 1 (1976) (finding Miranda warning was not required where IRS special agents met taxpayer in a home where he o......
  • Request a trial to view additional results
1 firm's commentaries
  • The Fifth Amendment And Civil Tax Enforcement
    • United States
    • Mondaq United States
    • 17 Julio 2013 decide whether silence was an invocation of the Fifth Amendment. Mathis v. United States, 391 U.S. 1 (1968). Beckwith v. United States, 425 U.S. 341 Reprinted with permission from the July 11, 2013 edition of the NEW YORK LAW JOURNAL © 2012 ALM Media Properties, LLC. All rights reserved.......
7 books & journal articles
  • Misdemeanor Defense
    • United States
    • James Publishing Practical Law Books Texas Small-firm Practice Tools. Volume 1-2 Volume 2
    • 5 Mayo 2022
    ...The Miranda warning is not a prerequisite for statements made while not under custodial interrogation. [ Beckwith v. United States , 425 U.S. 341 (1976).] The United States Supreme Court held that “testimonial statements” of witnesses absent from trial are admissible over a Sixth Amendment ......
  • Litigating miranda rights
    • United States
    • James Publishing Practical Law Books Suppressing Criminal Evidence Confessions and other statements
    • 1 Abril 2022
    ...while they are questioned, regardless of whether the person being questioned is the focus of an investigation. Beckwith v. United States , 425 U.S. 341 (1976). This includes questioning by a probation agent. Minnesota v. Murphy , 465 U.S. 420 (1984). The only exception occurs when the perso......
  • Misdemeanor defense
    • United States
    • James Publishing Practical Law Books Florida Small-Firm Practice Tools - Volume 1-2 Volume 2
    • 1 Abril 2023
    ...of Miranda The Miranda warning is a pre-requisite only for statements made while a suspect is in custody. [ Beckwith v. U.S. , 425 U.S. 341 (1976).] If a suspect makes incriminating statements to the police when he is not in custody, Miranda does not apply. [ Ross v. State , 45 So. 3d 403, ......
  • Confessions
    • United States
    • James Publishing Practical Law Books Texas Criminal Lawyer's Handbook. Volume 1-2 Volume 1
    • 5 Mayo 2022
    ...defendant has been taken into custody or otherwise deprived of his freedom of action in any significant way. Beckwith v. United States, 425 U.S. 341, 96 S.Ct. 1612, 48 L.Ed.2d 1 (1976). CONFESSIONS §6:22 Texas Criminal Lawyer’s Handbook 6-14 §6:21.9 Traff‌ic Stops Generally, a routine traff......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT