Caputo v. Nelson
United States Court of Appeals for the First Circuit
455 F.3d 45 (2006)
After Michael Caputo's (petitioner) estranged wife and mother-in-law were found murdered, police arrived at his home, read him his Miranda rights, and stopped questioning once he invoked his right to remain silent. An officer, Sergeant Dorman, later re-entered the house to use the phone and told his lieutenant over the call that Caputo's car (matching a suspect description) had a warm engine and two different license plates; Caputo, overhearing this, spontaneously volunteered a false alibi without being asked anything. After his motion to suppress that statement was denied and he was convicted, Caputo's habeas petition was denied by the federal district court, and he appealed.
Whether a police officer who uses tactics reasonably likely to elicit an incriminating response from a suspect is the functional equivalent of an interrogation in violation of the Fifth Amendment.