United States v. Eric Allen Manasen

We consider whether Eric Manasen was entitled to Miranda warnings before giving information to United States Customs officials in routine non-custodial questioning at the border.

BACKGROUND

Canadian Customs officials discovered that Manasen was a fugitive with an outstanding California warrant for his arrest when he arrived in Vancouver, B.C. on a flight from Singapore. They alerted United States Customs officials that he was traveling by bus to Seattle and gave his physical description and information that he might be using the alias “Alan Goodwin” and be carrying $15,000 in cash.

After Manasen arrived at the Blaine Port of Entry a customs agent had him complete a standard customs declaration form on which he identified himself as “Alan W. Goodwin” and checked the box which indicated he carried less than $10,000 in cash. He provided for identification a California driver’s license in the name “Alan W. Goodwin.”

When the inspection process was completed, another agent approached Manasen, informed him of the outstanding warrant and arrested him. Later, Canádian officials went to Blaine and identified him.

A jury convicted him of possession of false identification in violation…