United States v. Farid Ali
Docket: 1720
Court: Court of Appeals for the Second Circuit; May 22, 1996; Federal Appellate Court
In the case of United States v. Farid Ali, the Second Circuit Court of Appeals addressed the issue of whether Ali was in custody during his interrogation, which would necessitate Miranda warnings. Initially, the court had remanded the case for reconsideration of this custody determination. Ali petitioned for rehearing, arguing that the Supreme Court's ruling in Thompson v. Keohane required a de novo review of the custody issue, making remand unnecessary. The court agreed with Ali's position, noting that there were clear and undisputed facts surrounding his interrogation. It reiterated the established test for custody under Miranda, which considers whether a reasonable person in Ali's position would feel free to leave. The court highlighted that Ali was asked to step away from a boarding area, had his travel documents taken, and was surrounded by seven armed officers, with testimony indicating he would not have been allowed to leave had he attempted to do so. Based on these circumstances, the court concluded that Ali was indeed in custody, and therefore, Miranda warnings were required but not provided. As a result, the statements made during the interrogation were improperly used against him at trial. The court vacated Ali's conviction and remanded the case for a new trial, instructing that the new proceedings align with its prior opinion.