United States v. Coulter (5th Cir. July 2022)
Fifth Circuit, Miranda, Recent Circuit Cases|
The Fifth Circuit reversed a district court’s order suppressing statements a defendant made without Miranda warnings while the defendant was handcuffed and detained after a traffic stop. The Court reasoned that no reasonable person would believe they were in custody, since the defendant had indicated he knew he was being handcuffed and detained for “officer safety,” and thus would not have believed he was under arrest.