On the Job 

United States v. Crumpton, 2016 U.S. App. LEXIS 9993 (6th Cir. June 2, 2016)
In this case, the 6^th Circuit Court of Appeals addressed whether an officer is required to tell a suspect, as part of the Miranda rights, that he or she has a right to stop answering questions at any time.

Brief Facts: Law enforcement executed a search warrant at the Detroit home of Kelvin Crumpton for a drugs and firearms investigation. Prior to questioning Crumpton, an agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives offered the following warnings:

(1) “The right to remain silent;” (2) that “anything you say can be used against you in court;” (3) “the right to consult with an attorney and have them present during questioning;” and (4) that “if you cannot afford an attorney, one will be appointed to represent you prior to questioning.”

After the warnings, Crumpton made an incriminating statement. During a second interview, Crumpton was again read his Miranda rights, however the agent added a fifth warning that said “if you decide to answer any questions now without a lawyer present, you have the right to stop answering questions at any time.”

Crumpton eventually made more incriminating statements. The district court suppressed Crumpton’s statement because the agent didn’t tell Crumpton he had the right to stop answering questions during the first reading of Miranda. The government appealed to the 6^th Circuit Court of Appeals.

Court’s Findings: The court examined the warnings read to Crumpton and reversed the district court. The district court made clear that officers are only required to read a suspect the enumerated four warnings above. The court noted that a defendant need not be informed of a right to stop questioning after the questioning has begun. As a result, the statements made by Crumpton were admissible against him at trial.