United States v. Young.
No. 18-6221. W.D.Okla. Judge Lucero. Motion to Suppress Confession—Coercion—Misrepresentations by Officer—Voluntariness of Confession.
June 15, 2020
A deputy observed defendant’s vehicle swerving on a roadway and signaled him to stop. Defendant continued to drive and ultimately stopped in a residential area and fled on foot. The deputy pursued and arrested defendant. After the arrest, the deputy retraced defendant’s path and found a case containing four grams of a substance containing methamphetamine. Later that day, officers returned to the area and found a bag containing 93 grams of a substance containing methamphetamine near where defendant stopped his car. Defendant admitted to possessing the smaller quantity but denied the larger quantity was his. He then cut off questioning and revoked his consent to speak.
Several days later an FBI agent interrogated defendant in the county jail. During the interrogation, the agent invoked his purported relationship with the judge numerous times and stated that he would speak with the judge about leniency if defendant was honest. The agent also made representations about the sentence defendant would face. After waiving his Miranda rights, defendant confessed to possessing the larger quantity. Following the confession, defendant was charged with possession with intent to distribute. Defendant moved to suppress the second confession as involuntary. The court held a hearing, and although it found that the agent made false representations and improper promises of leniency, it concluded that the confession was not involuntary, and it denied the motion to suppress.
On appeal, defendant argued that the district court erred in denying his motion to suppress. He argued that the confession was involuntary because the officer who interrogated him deceived him about having access to the federal judge on the case. Here, the agent misrepresented the sentence defendant faced and the leniency that would be afforded him if he cooperated, and he made improper and false statements about his access to a federal judge. Defendant confessed within minutes of these statements. Under the totality of the circumstances, the agent’s conduct was coercive and defendant’s capacity for self-determination was critically impaired, rendering the confession involuntary.
The decision was reversed, the judgment was vacated, and the case was remanded for further proceedings.