United States v. Daniels, No. 18-3049 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that inculpatory statements defendant made during his state parole revocation hearing related to possession of the firearm were properly admitted. In this case, defendant testified voluntarily under oath after being informed of his right to counsel and his right to remain silent, and was warned that any statements he made could be used against him in the revocation proceeding and other criminal proceedings.
The court also held that the district court did not abuse its discretion in granting the government's motion in limine to exclude the passenger's prior conviction. Furthermore, any error in admitting the evidence was harmless in light of defendant's admission that he knowingly possessed the firearm found in the car. Finally, although defendant should have been Mirandized before any custodial interrogation, the court held that his admissions were properly admitted at trial and rendered any Miranda violation harmless beyond a reasonable doubt.
Court Description: Erickson, Author, with Colloton and Gruender, Circuit Judges] Criminal Case - Conviction. The district court did not abuse its discretion in denying motion in limine to exclude admission of statements Daniels made a his state parole revocation hearing relating to possession of a firearm; he voluntarily testified after being advised of his right to counsel and right to remain silent, and that his statements could be used against him and there were no other dangers of unfair prejudice. District court did not abuse its discretion in granting government's motion in limine to exclude passenger's prior conviction; any error was harmless because Daniels admitted his own possession. District court's denial of his motion to suppress statements made prior to receiving Miranda warnings were also harmless error in light of other admissions. [ August 02, 2019
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