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United States v. Abdulmutallab
United States District Court for the Eastern District of Michigan
2011 WL 4345243 (2011)
Umar Farouk Abdulmutallab (defendant), a Nigerian citizen, was indicted in federal district court after he attempted to ignite explosives concealed in his underwear while flying as a passenger from Amsterdam to Detroit, Michigan. During his planned attack, Abdulmutallab successfully lit his pants and the side of the aircraft on fire. Nearby passengers subdued Abdulmutallab while the flames were extinguished. During the incident, Abdulmutallab suffered significant burns and was taken by U.S. Customs and Border Protection officers to the University of Michigan Hospital for medical treatment. Later, Abdulmutallab was questioned at the hospital by Federal Bureau of Investigation (FBI) agents. During the 50-minute questioning, Abdulmutallab admitted to possessing and attempting to use the explosives to blow up the plane on behalf of al-Qaeda. However, the federal agents did not advise Abdulmutallab of his Miranda rights, fearing that there was little time to prevent possible additional, imminent aircraft attacks. Prior to trial, Abdulmutallab filed a motion to suppress his statements made prior to the issuance of his Miranda warnings. The federal government argued that Abdulmutallab’s pre-Miranda statements were admissible under the public-safety exception to Miranda rights, which was articulated in New York v. Quarles, 467 U.S. 649 (1984).
Rule of Law
Holding and Reasoning (Edmunds, J.)
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