United States v. Capps, No. 13-1196 (8th Cir. 2013)
Annotate this CaseDefendant appealed his conviction for possession with intent to distribute fifty grams or more of methamphetamine and sentence of a mandatory term of life in prison. The court concluded that the district court did not err in denying defendant's motion to suppress evidence seized from a vehicle where the absence of a Miranda warning prior to the search did not nullify defendant's otherwise voluntary consent and where an objectively reasonable person would have understood defendant to have consented to a search of the entire vehicle. The court also concluded that defendant's sentence did not violate the Eighth Amendment where, in light of his two prior drug convictions, his sentence was not grossly disproportionate. Accordingly, the court affirmed the conviction and sentence.
Court Description: Criminal case - Criminal law and Sentencing. Failure to give Miranda warning prior to asking defendant to consent to a search did not nullify defendant's otherwise voluntary consent; search of defendant's vehicle did not exceed the scope of defendant's consent; mandatory life sentence pursuant to 21 U.S.C. Sec. 841(b)(1)(A)(viii) does not violate the Eighth Amendment; Miller v. Alabama, 132 S. Ct. 2455 (2012) does not disturb existing circuit precedent foreclosing defendant's argument that his sentence is grossly disproportionate. [ June 10, 2013
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