Minnesota v. Murphy
Citation and Court
465 U.S. 420 (1984) — Supreme Court of the United States
Facts
Murphy, a probationer, was required to meet regularly with his probation officer and to be truthful. During a meeting, his probation officer questioned him about a rape and murder; Murphy admitted involvement. He argued the statement was inadmissible because he was not given Miranda warnings.
Issue
Whether a probationer who is required to meet with his probation officer and answer questions truthfully is “in custody” for Miranda purposes, and whether his failure to claim the privilege forecloses its protection.
Holding
Murphy was not in custody during the meeting, so Miranda did not apply; and because he did not invoke the privilege when questioned, he waived it and his incriminating statements were admissible.
Rule / Doctrine
Custody for Miranda purposes requires a formal arrest or restraint on freedom of movement of the degree associated with arrest. A required probation meeting, while compelled attendance, does not involve the coercive, police-dominated atmosphere that Miranda was designed to address. Additionally, the Fifth Amendment privilege must be affirmatively claimed; silence in the face of questioning is not sufficient to invoke it.
Significance
Clarified that the Miranda custody standard does not extend to all compelled encounters with government officials. Probationers must affirmatively assert the privilege if they wish to avoid self-incrimination during probation meetings.