Question: Does a suspect of a crime have to receive a Miranda Warning prior to being questioned by the police?
Answer: Not always.
In 2012, an officer noticed a car with heavy front-end damage in a ditch and saw a man, later identified as Matheny, sitting in the driver’s seat of the car. The officer asked Matheny what had happened. Another officer was informed that this car had been reported stolen after running its plate. The officers then approached Matheny. During the patdown, the officer felt a wallet in Matheny’s pocket. Because they had been unable to identify him, the officer removed the ID card from the wallet. Matheny was the name on the card. To confirm whether the ID was in fact Matheny’s, the officer asked Matheny for his address, but he did not answer. Finally after repeated questions, Matheny said that he lived at Wheeler Mission. Thereafter, the State charged Matheny with felony auto theft. Matheny filed a motion to suppress evidence, but the trial court concluded that Matheny had been too intoxicated to knowingly and voluntarily waive his Miranda rights and therefore suppressed all Matheny’s statements made after he was taken into custody, except for those concerning his identifying information. At trial, Matheny objected to the admission of his statement that he lived at Wheeler Mission. The trial court concluded that “routine questions for the purposes of identification, such as name, address, height, weight are not within the purview of Miranda,” and admitted the statement. An officer testified that Wheeler Mission was close to where the car had been parked and the jury found Matheny guilty of felony auto theft.
On appeal, Matheny contends that his statement that he lived at Wheeler Mission was obtained in violation of the Fifth Amendment to the United States Constitution, which provides that no person shall be compelled in any criminal case to be a witness against himself. The privilege against self-incrimination protects individuals not only from the legal compulsion to testify in a criminal courtroom, but also from the informal compulsion exerted by law-enforcement officers during in-custody questioning. Thus, when a person is in custody and is subject to interrogation, the accused must be adequately and effectively apprised of his rights and the exercise of those rights must be fully honored. In sum, statements that are the product of custodial interrogation prior to the advisement of the Fifth Amendment guarantee against self-incrimination are generally inadmissible. Nevertheless, there are some police questions which do not fall within Miranda’s purview. Questions regarding name, address, height, weight, eye color, date of birth, and current age are outside the scope of Miranda’s coverage. Matheny contends that the manner in which the officer elicited the statement from him that he lived at Wheeler Mission shows that the inquiry was not made for recordkeeping purposes or as part of the booking process following arrest, and the statement was an important piece of evidence in the State’s case against him. Here, the officer testified that his reason for asking him for his address was to verify the information on the ID. As such, the officer’s questions were outside the scope of Miranda. The fact that Matheny’s residence was ultimately incriminating does not retroactively transform the routine identification questions into interrogation for purposes of Miranda. Accordingly, we conclude that the trial court did not abuse its discretion in admitting Matheny’s answer.
Matheny v. State, 983 N.E.2d 672 (Ind.App. 2013)