Beckwith v. United States

• Citation: 425 U.S. 341,48 L.Ed.2d 1,96 S.Ct. 1612
• Decision Date: 21 April 1976
• Docket Number: No. 74-1243,74-1243
• Parties: Alvin A. BECKWITH, Jr., Petitioner, v. UNITED STATES
• Court: United States Supreme Court

48 L.Ed.2d 1

96 S.Ct. 1612

425 U.S. 341

Alvin A. BECKWITH, Jr., Petitioner,

v UNITED STATES.

No. 74-1243.

Argued Dec. 1, 1975.

Decided April 21, 1976.

Syllabus

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 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- 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 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 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 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. United States, 391 U.S. 1, 88 S.Ct. 1503, 20 L.Ed.2d 381 (1968). See generally Schneckloth v. Bustamonte, 412 U.S. 218, 247, 93 S.Ct. 2041, 2058, 36 L.Ed.2d 854, 874 (1973).

Petitioner's argument that he was placed in the functional, and, therefore, legal, equivalent of the Miranda situation asks us now to ignore completely that Miranda was grounded squarely in the Court's explicit and detailed assessment of the peculiar "nature and setting of . . . in-custody interrogation," 384 U.S., at 445, 86 S.Ct. at 1612, 16 L.Ed.2d at 707. That Courts of Appeals have so read Miranda is suggested by Chief Judge Lumbard in United States v. Caiello, 420 F.2d 471, 473 (CA2 1969):

" 'It was the compulsive aspect of custodial interrogation, and not the strength or content of the government's suspicions at the time the questioning was conducted, which led the court to impose the Miranda requirements with regard to custodial questioning.' "

Mathis v. United States, supra, directly supports this conclusion in holding that the Miranda requirements are applicable to interviews with Internal Revenue agents concerning tax liability, When the subject is in custody ; the Court thus squarely grounded its holding on the custodial aspects of the situation, not the subject matter of the interview.⁸

An interview with Government agents in a situation such as the one shown by this record simply does not present the elements which the Miranda Court found so inherently coercive as to require its holding. Although the "focus" of an investigation may indeed have been on Beckwith at the time of the interview in the sense that it was his tax...