Thompson v. Keohane

Background

Carl Thompson, a man arrested in Alaska for his ex-wife’s murder, went to state trooper headquarters after officers asked him to identify personal items. He was questioned for about two hours by two unarmed troopers in a small interview room, tape-recorded, and not given Miranda warnings. Thompson confessed, was later arrested, tried, and convicted, and he challenged his conviction in federal habeas court claiming the confession should have been suppressed because he was not warned.

Reasoning

The Court considered whether the state courts’ finding that Thompson was not “in custody” is a simple factual finding entitled to a federal presumption of correctness under 28 U.S.C. § 2254(d), or a mixed question of law and fact requiring independent federal review. The Court held the “in custody” issue is a mixed question: state courts’ findings about the scene and what happened are factual and get a presumption, but the ultimate legal question—whether a reasonable person in the suspect’s position would have felt free to leave—requires application of law to those facts and merits independent federal review. The Supreme Court vacated the Ninth Circuit’s judgment and remanded the case for further proceedings.

Real world impact

Federal habeas courts can independently decide whether Miranda warnings were required instead of always deferring to state rulings. This affects people challenging confessions on federal habeas review and guides police and courts on when warnings must be given; the decision does not itself suppress Thompson’s confession but sends the case back for further review.

Dissents or concurrances

Justice Thomas dissented, arguing the state trial judge was better placed to judge custody and that the state court’s decision should have been presumed correct.