Rhode Island v. Innis

Facts

On the night of January 12, 1975, a Providence taxicab driver, John Mulvaney, disappeared. His body was found four days later in a shallow grave, killed by a shotgun blast to the back of the head. On January 17, 1975, another cab driver, Aubin, reported that a man with a sawed-off shotgun had just robbed him. Aubin picked out Innis from a photo array. About 4:30 a.m., Patrolman Lovell arrested Innis, who was unarmed, in the Mount Pleasant area and gave him Miranda warnings. Sergeant Sears and Captain Leyden also warned him. Innis said he understood his rights and wanted to speak with a lawyer. Leyden had him put in a police wagon to be driven to the central station, with three officers, and told them not to question, intimidate or coerce him. On the way, Patrolman Gleckman told Patrolman McKenna that handicapped children from a nearby school might find the missing shotgun and hurt themselves. McKenna agreed it was a safety concern. Patrolman Williams said nothing but heard it all. Innis then interrupted and asked the officers to turn around so he could show them the gun. They had gone no more than a mile. Back at the scene, Leyden warned him again, and Innis led the police to the shotgun.

Issues

1. What does "interrogation" mean under Miranda v. Arizona when a suspect in custody has asked for a lawyer, and does it reach more than express questioning?
2. Was Innis "interrogated" when two officers talked to each other in his hearing about the danger of the missing shotgun to handicapped children?

Holding

Innis was not interrogated. The officers did not question him, and the Court could not say they should have known that their brief conversation, which appeared to consist of no more than a few offhand remarks, was reasonably likely to elicit an incriminating response. The Court did not reach whether Innis waived his right to counsel.