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Name: United States v. Chen
Case #: 05-10108
Court: US Court of Appeals
District 9 Cir
Opinion Date: 03/02/2006
Summary

Chen made statements during an interview with an INS agent who was investigating a third party, Li, who was suspected of running an alien smuggling ring. The agent had questioned Chen about how he had arrived in Guam, and Chen gave him an answer which proved untrue. Chen was indicted for perjury, and the prosecutor admitted his intent was to pressure Chen to cooperate in the prosecution against Li. At the time of the interview, Chen was in custody on an administrative deportation warrant. The district court suppressed the statements because of the failure to give Chen a Miranda warning prior to the interview. The prosecutor appealed, and the appellate court affirmed the trial court’s ruling. The prosecutor’s interest in prosecuting Chen in order to get to Li, coupled with the fact that Chen was questioned in a district likely to prosecute misdemeanor illegal entry, rendered the questioning an interrogation for Miranda purposes. It was unnecessary to decide whether questioning which would elicit an alien’s admission of illegal presence in the United States will always constitute an interrogation for Miranda purposes.