United States v. Terry Covington

SCHROEDER, Circuit Judge,

dissenting.

The defendant is an American citizen employed at the Kwajalein Missile Range who was indicted pursuant to 18 U.S.C. § 2032. The majority correctly recognizes that admission of the defendant’s confession would violate the principles enunciated in Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966), and Edwards v. Arizona, 451 U.S. 477, 101 S.Ct. 1880, 68 L.Ed.2d 378 (1981), which protect rights guaranteed by the fifth and sixth amendments of the United States Constitution. The law of the Republic of the Marshall Islands also requires its exclusion.1 We can agree, therefore, that if the defendant was arrested, interrogated and prosecuted under the same law, be it American or Marshallese, the confession would be inadmissible. Here, however, the majority ironically holds that the confession is admissible if it was the product of Marshallese law enforcement because Covington is being prosecuted under United States law in United States courts.

In so holding, the court reasons that the law of the Marshall Islands applicable to this proceeding is as foreign to the law of the United States as the law of Transylvania. It further asserts that application of our standards would have no affect on conduct of law enforcement agents of the Marshall Islands in dealing with American personnel and would not deter them from taking actions which the American legal system disapproves.

This is mistaken. The relationship between the law of the United States and the law of the Marshall Islands is special. The United States has taken great pains to ensure that its personnel in the Marshall Islands, including defendant, are afforded all the protections provided by United States law regardless of whether they are prosecuted under the law of the Marshall Islands or, as here, of the United States. The United States, given its permanent presence in the Marshall Islands and its connection with law enforcement on Kwajalein atoll, possesses an undeniable interest in influencing police conduct.

The governments of the United States and the Marshall Islands have a unique historic relationship.2 See Commonwealth of Northern Mariana Islands v. Atalig, 723 F.2d 682, 684 (9th Cir.), cert. denied, — U.S. -, 104 S.Ct. 3518, 82 L.Ed.2d 826 (1984); In re Bowoon Sangsa Co., 720 F.2d 595, 600-601 (9th Cir.1983); Gale v. Andrus, 643 F.2d 826, 828-30 (D.C.Cir.1980); Clark, Self-Determination and Free Association — Should the United Nations Terminate the Pacific Islands Trust?, 21 Harv.Int’l.LJ. 1, 1-8 (1980). The Marshall Islands are part of the Trust Territory of Micronesia, which covers over 2,000 islands in the western Pacific Ocean. Since 1947, the United States has acted as trustee for the territory. Gale, 643 F.2d at 828; Trusteeship Agreement for the Former Japanese Mandated Islands, July 18, 1947, 61 Stat. 3301, T.I.A.S. No. 1665, 8 U.N.T.S. 189. In the four decades that followed assumption of the trusteeship, the United States has delegated sufficient au*1058thority to the territory to have it deemed an independent sovereign. See Atalig, 723 F.2d at 684; Gale, 643 F.2d at 828; McComish v. C.I.R., 580 F.2d 1323, 1331 (9th Cir.1978).

At present, pursuant to Article VI of the Trusteeship Agreement, in which the United States assumed the responsibility of promoting the development of self-government by the inhabitants of the Islands, Gale, 643 F.2d at 829, the Marshall Islands has elected to assume the status of a “free association,” which would continue to confirm upon it independent sovereignty. In re Bowoon Sangsa Co., 720 F.2d at 600.3 The present status of the Marshall Islands, however, is somewhat unclear as it is in a “transitional phase” between the status of trust territory and free association.

The terms of the status of free association evolved through negotiation between the United States and the Republic of the Marshall Islands. Fourteen years of negotiations have led to the signing of the Compact of Free Association, which is the basic document setting forth the relationship between the two governments under the status of free association. Compact of Free Association, June 25, 1983, United States— Republic of the Marshall Islands, S.Rep. 626, 98th Cong.2d Sess. 34 (1984) (unratified and resubmitted to the House of Representatives on Feb. 20, 1985), Office for Micronesian Status Negotiations, Washington, D.C.; see also President’s Message to Congress Accompanying Free Compact of Association, Mar. 30, 1984, 1984 U.S. Code Cong. & Ad.News D33 (urging congressional approval of Compact). See generally Clark, supra, at 11-38. While the Compact of Free Association, as of now, remains unratified by Congress, it has been approved by the President under the authority granted to him pursuant to 48 U.S.C. § 1681.4 The Compact of Free Association, though not in full force and effect, articulates clear and deepfelt concerns that the United States desires to be applied to its personnel and citizens in the Marshall Islands.

The Compact of Free Association is supplemented by various agreements, one of which is the Status of Forces Agreement, May 24, 1982, United States — Republic of the Marshall Islands, Office for Micronesian Status Negotiations, Washington, D.C., which further defines the legal status of United States personnel in the Marshall Islands. The Status of Forces Agreement deals with problems arising from the permanent presence of United States military forces in the Islands. It is agreed by all that these are also expressions of policy which should be followed. Under the Status of Forces Agreement, where, as in this case, an employee of the United States military forces is charged with a serious crime, he may be tried in either a court of the Marshall Islands, or a court of the United States. Id. at art. 12, § 2(b). The Status of Forces Agreement also guarantees that where such personnel are prosecuted in the courts of the Marshall Islands, they shall be entitled to many of the rights and protections of United States law, including protection from the use of a confession obtained by illegal or improper means:

United States personnel prosecuted under the jurisdiction of ... the Marshall Islands ... shall be entitled to all guarantees and rights provided by the constitution and laws of the prosecuting *1059Government for its own citizens and to the following guarantees and rights to the extent that they are not provided by that constitution and those laws:
(l) To be protected from the use of a confession or other evidence obtained by unlawful or improper means;

Id. at § 9 (emphasis added).

This particular provision is but one of many provisions designed to ensure that American military personnel in the Marshall Islands will be afforded the same protections regardless of which government, the Marshall Islands or the United States, undertakes the prosecution. Some of the other protections specifically provided are for a prompt and speedy trial, id. at § 9(a), right of confrontation, id. at (d), right to public trial, id. at (j), and right of appeal, id. at (p). The United States clearly has asserted its strong interest in deterring undesirable conduct by agents enforcing the law of the Marshall Islands when that conduct is directed at United States personnel.

The majority relies on United States v. Chavarria, 443 F.2d 904 (9th Cir.1971), where we held that violation of Miranda standards did not render a confession to a Mexican police officer inadmissible. We did so because, given the relationship between the United States and Mexico, the United States had neither an interest in affecting nor an ability to affect the conduct of Mexican law enforcement officers. As the Chavarria court stated,

Miranda was intended as a deterrent to unlawful police interrogations. When the interrogation is by the authorities of a foreign jurisdiction, the exclusionary rule has little or no effect upon the conduct of foreign police. Therefore, so long as the trustworthiness of the confession satisfies legal standards, the fact that the defendant was not given Miranda warnings before questioning by foreign police will not, by itself, render his confession inadmissible.

Id. at 905.5

The situation here, however, is different. The protections of Miranda are relevant because the police officers are hired by the United States military and, though they enforce Marshallese law, they enforce it almost solely against Americans. The United States, because it hires the police, who are Americans, to enforce Marshallese law against Americans, on an atoll exclusively controlled by the American military, has an interest in affecting, and can affect, the conduct of the police whose actions violate both Marshallese6 and United States7 law. Cf. United States v. Trenary, 473 F.2d 680, 681 (9th Cir.1973) (stating in dicta that Miranda is inapplicable when the foreign arrest violated no foreign law) (citing United States v. Nagelberg, 434 F.2d 585 (2d Cir.1970), cert. denied, 401 U.S. 939, 91 S.Ct. 935, 28 L.Ed.2d 219 (1971)). The efforts of the United States during the transition of the Marshall Islands from trust territory to free association underscores the American interest in maintaining and insuring for Americans, who are subject to prosecution in the courts of the Marshall Islands, the protec*1060tions that Americans enjoy in the courts of the United States.

By ignoring the strong interest of the United States, the majority manages to reach a peculiar result which conflicts with our policies toward the Marshall Islands. Under today’s decision, this defendant, an American citizen prosecuted in the courts of his own country pursuant to United States law, may be entitled to fewer protections than if he were prosecuted in the courts of the Marshall Islands under Marshallese law. The protections should be the same. I would affirm the district court.

. In this instance, the foreign law mirrors ours. The Republic of the Marshall Islands itself has adopted the Miranda doctrine to guarantee certain rights of the defendants it prosecutes. The Marshall Islands has incorporated the Miranda doctrine into its constitution, Republic of the Marshall Islands Const, art. II, § 4, and into its statutes, 12 T.T.C. § 68. The courts of the Trust Territory also apply the doctrine. Trust Territory v. Techur, 7 T.T.R. 412, 416-17 (1976); Trust Territory v. Remengesau, 6 T.T.R. 94, 96-97 (1972); Trust Territory v. Sokau, 4 T.T.R. 434, 436-38 (1969); Trust Territory v. Poll, 3 T.T.R. 387, 391-92 (1968). Hence, both the United States and the Marshall Islands employ Miranda as a vital legal doctrine for the protection of significant constitutional rights.

. What the D.C. Circuit observed in another trust territory case is equally true here: "If one fails to appreciate the true characteristics of this unique relationship for purposes of this case, it is easy to get lost ... trying to pigeonhole or label this entity called [the Marshall Islands]." Gale v. Andrus, 643 F.2d 826, 830 (D.C.Cir.1980).

. For a scholarly discussion of the doctrine of free association, see generally Clark, supra, at 38-66.

. Section 1681(a) provides:

Until Congress shall further provide for the government of the Trust Territory of the Pacific Islands, all executive, legislative, and judicial authority necessary for the civil administration of the Trust Territory shall continue to be vested in such person or persons and shall be exercised in such manner and through.such agency or agencies as the President of the United States may direct or authorize.

Congress, thereby, delegated its administrative responsibility under the Trusteeship Agreement to the President, who then delegated it to the Department of Interior. Exec. Order No. 11021, 27 Fed.Reg. 4409 (Mar. 9, 1962). For a general discussion of the statutory and regulatory framework, see Gale, 643 F.2d 826.

. Chavarria, 443 F.2d 904, and United. States v. Trenary, 473 F.2d 680 (9th Cir.1973), have led to a "foreign police officer" exception to Miranda. Under this exception, Miranda does not apply when the arrest and interrogation is by a foreign officer in a foreign country, see Chavarria, 443 F.2d at 905, absent a showing that the statement was either coerced or taken in violation of the laws of the foreign country, see Trenary, 473 F.2d at 681, or that a joint venture existed between the authorities of the foreign country and the United States, see United States v. Emery, 591 F.2d 1266, 1267 (9th Cir.1978). Other circuits have fashioned a similar exception. See, e.g., United States v. Nolan, 551 F.2d 266, 273 (10th Cir.), cert. denied, 434 U.S. 904, 98 S.Ct. 302, 54 L.Ed.2d 191 (1977); United States v. Nagelberg, 434 F.2d 585 (2d Cir.1970), cert. denied, 401 U.S. 939, 91 S.Ct. 935, 28 L.Ed.2d 219 (1971).

. Footnote 1 supra.

. Edwards, 451 U.S. 477, 101 S.Ct. 1880, 68 L.Ed.2d 378; Miranda, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694.