Mathis v. United States

Petitioner, who was in a state prison, was questioned by an Internal Revenue Service investigator about certain tax returns in a "routine tax investigation," without any warnings that any evidence he gave could be used against him, that he had a right to remain silent, and a right to counsel, or that one would be appointed for him if he was unable to afford counsel. Documents and oral statements obtained from petitioner were introduced in his criminal trial for filing false claims for tax refunds. He was convicted and his conviction was affirmed by the Court of Appeals.

Held: Pursuant to Miranda v. United States, 384 U.S. 436 (1966), petitioner was entitled to warnings of his right to be silent and right to counsel. Tax investigations, which frequently lead to criminal prosecution, are not immune from the Miranda warning requirement to be given to a person in custody, whether or not such custody is in connection with the case under investigation. Pp. 3-5.

376 F. 2d 595, reversed and remanded.

Nicholas J. Capuano, by appointment of the Court, 389 U. S. 966, argued the cause and filed a brief for petitioner.

Daniel M. Friedman argued the cause for the United States. On the brief were Solicitor Greneral Griswold, Assistant Attorney General Rogovin, and Joseph M. Howard.